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POBRE VS MIRIAM DEFENSOR SANTIAGO disciplinary proceeding under the Rules of Court.

The disciplinary actions falls under the Congress

FACTS: JBC through public invitation publish the provided in The Rules of the Senate contains a
soon vacant position of Chief of Justice, hence provision on Unparliamentary Acts and Language
Santiago was one of the applicant but that enjoins a Senator from using, under any
unfortunately informed by the JBC that only circumstance, offensive or improper language
incumbent associate justice would qualify the against another Senator or against any public
position. During her privilege speech on the institution. Senate President had not apparently
Congress to wit; “x x x I am not angry. I am irate. called her to order, let alone referred the matter to
I am foaming in the mouth. I am homicidal. I am the Senate Ethics Committee for appropriate
suicidal. I am humiliated, debased, degraded. And I disciplinary action, as the Rules dictates under such
am not only that, I feel like throwing up to be living circumstance. The lady senator clearly violated the
my middle years in a country of this nature. I am rules of her own chamber. Therefore the
nauseated. I spit on the face of Chief Justice disbarment case proceeding was DISMISSED.
Artemio Panganiban and his cohorts in the
Supreme Court, I am no longer interested in the
position [of Chief Justice] if I was to be surrounded
by idiots. I would rather be in another environment
but not in the Supreme Court of ANTERO
J. POBRE in his sworn letter/complaint invites the
attention of the court and asks that disbarment
proceedings or other disciplinary actions be taken
against the lady senator.

Issue: Does the disbarment proceeding and other

disciplinary actions should be taken against the


NO, because the delivery of speech was conducted

while the Congress is in session and therefore she
is covered with the state immunity provided in our
Constitution Art. VI Sec.11 of the Constitution.
Indeed, her privilege speech is not actionable
criminally or in a disciplinary proceeding under the
Rules of Court. The plea of Senator Santiago for the
dismissal of the complaint for disbarment or
disciplinary action is well taken. Indeed, her
privilege speech is not actionable criminally or in a