FACTS:

In late 2001 House of Representatives (HOR) of

the 12th Congress adopted its Rules of Procedure
in Impeachment Proceedings. The new rules
superseded = “outdated” impeachment Rules of the
11th Congress. Secs. 16 and 17 of these Rules
state that impeachment proceedings are deemed =
“thought, believe, considered” initiated (1) if
House Committee on Justice deems the complaint
sufficient in substance, or (2) if the House
itself affirms or overturns the findings of the
House Committee on Justice on the substance of
the complaint, or (3) by filing or endorsement
before the HOR Secretary General by one-thirds
of the members of the House.

A few months later, HoR passed a resolution

directing the Committee on Justice to conduct an
investigation, in aid of legislation, on the
manner of disbursements and expenditures by
Chief Justice Davide of the Judiciary
Development Fund (JDF).”

In June 2003, former President Estrada files the

first impeachment complaint against Chief
Justice Davide and 7 Associate Justices of SC
for “culpable violation of the Constitution,
betrayal of public trust and other high crimes.”
The complaint was referred to the House
Committee on Justice on August 5, 2003 in
accordance with Section 3(2) of Article XI of
the Constitution.
On October 13, 2003, the HOR Committee on
Justice found the first impeachment complaint
“sufficient in form.” However, it also voted to
dismiss the same on October 22, 2003 for being
insufficient in substance. Ten days later, on
October 23,2003, Teodoro and Fuentebella filed a
second impeachment complaint against CJ Davide,
founded on the alleged results of the
legislative inquiry on the JDF. The second
impeachment complaint was accompanied by a
“resolution of Endorsement/Impeachment” signed
by at least one-third of all the Members of the
House of Representatives.

Several petitions were filed with the SC by

members of the bar, members of the House of
Representatives, as well as private individuals,
all asserting their rights, among others, as
taxpayers to stop the illegal spending of public
funds for the impeachment proceedings against
the Chief Justice. The petitioners contend that
Article XI, Section 3 (5) of the 1987
Constitution bars the filing of the second
impeachment complaint. The constitutional
provision states that “(n)o impeachment
proceedings shall be initiated against the same
official more than once within a period of one
year.”

Speaker Jose de Venecia submitted a

manifestation to the SC stating that the High
Court does not have jurisdiction to hear the
case as it would mean an encroachment on the
power of HoR, a co-equal branch of government.
ISSUES/HELD:

1.) Whether the filing of the second impeachment

complaint violates Sec. 3(5), Article XI of the
Constitution—YES

2) Whether Sec. 16 & 17 of Rule V of the Rules

of Procedure in Impeachment Proceedings approved
by the HoR are unconstitutional – YES

3.) Whether or not the certiorari jurisdiction

of the court may be invoked – YES

RATIO:

1. The second impeachment complaint falls under

the one-year bar under the Constitution.

2. Sec 16 and 17 of House Impeachment Rule V are

unconstitutional.

The Supreme Court employed three principles in

deciding the case:

1) Whenever possible, the words in the

Constitution must be given their ordinary
meaning (verbal legis);

2) If there is ambiguity, the Constitution must

be interpreted according to the intent of the
framers; and

3) The Constitution must be interpreted as a

whole.
Applying these principles, to “initiate” in its
ordinary acceptation means simply to begin. The
records of the debates by the framers affirm
this textual interpretation. From the records of
the Constitutional Convention and the amicus
curiae briefs of its two members (Maambong and
Regalado), the term “to initiate” in Sec 3(5),
Art. XI of the Constitution refers to the filing
of the impeachment complaint coupled with taking
initial action by Congress on the complaint.

By contrast, Secs. 16 and 17 state that

impeachment proceedings are deemed initiated (1)
if House Committee on Justice deems the
complaint sufficient in substance, or (2) if the
House itself affirms or overturns the findings
of the House Committee on Justice on the
substance of the complaint, or (3) by filing or
endorsement before the HOR Secretary General by
one-thirds of the members of the House.

In this light, Secs. 16 and 17 of the House

Rules of Procedure for Impeachment are
unconstitutional because the rules clearly
contravene Sec. 3 (5), Art. XI since the rules
give the term “initiate” a different meaning
from filing and referral.

Hence, the second impeachment complaint by

Teodoro and Fuentebella violates the
constitutional one-year ban.

3. The certiorari jurisdiction of the court may

be invoked.
The Supreme Court, in exercising its expanded
power of judicial review, only carried out its
duty as stated in Section 1, Article VIII, which
mandates the judicial department to look into
cases where there has been a grave abuse of
discretion on the part of the different branches
of government. Here, it only reviewed the
constitutionality of the Rules of Impeachment
against the one-year ban explicitly stated in
the Constitution. Consequently, the contention
that judicial review over the case would result
in a crisis is unwarranted.

The judiciary, with the Supreme Court at its

helm as the final arbiter, effectively checks on
the other departments in the exercise of its
power to determine the law. It must declare
executive and legislative acts void if they
violate the Constitution. The violation of
Article XI, Section 3(5) of the Constitution is
thus within the competence of the Court to
decide.