2012-02-25 Comment Adaza Petitions as of 530PM

8/2/2019 2012-02-25 Comment Adaza Petitions as of 530PM

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REPUBLIC OF THE PHILIPPINESSUPREME COURT

MANILA

En Banc

ATTY. VICENTE D. MILLORA,Petitioner,

- versus - G.R. No. 199535

THE HONORABLE HOUSE OFREPRESENTATIVES,SPEAKER FELICIANOBELMONTE, CHAIRMAN NIELTUPAS, JR., COMMITTEE OFJUSTICE, THE 188 MEMBERSOF THE HOUSE WHO SIGNEDTHE IMPEACHMENTARTICLE(S) DATED

DECEMBER 12, 2011AGAINST CHIEF JUSTICERENATO CORONA, AND THEHONORABLE SENATE OF THEPHILIPPINES,

Respondents.

x------------------------------------------x

CITIZENS HOMOBONO A.ADAZA and ALAN PAGUIA,

Petitioners,

-versus-

HOUSE OF

REPRESENTATIVES,CONGRESS OF THEPHILIPPINES, representedby HOUSE SPEAKERFELICIANO BELMONTE andSENATE OF THEPHILIPPINES, represented

G.R. No. 199694


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Consolidated CommentAd Cautelam Ex SuperabundantiAtty. Vicente D. Millora vs. The Honorable House of Representatives et al.G.R. No. 199535, et al.

by SENATE PRESIDENT JUANPONCE ENRILE,

Respondents.

x------------------------------------------xDANILO A. LIHAYLIHAY,

Petitioner,

-versus-

THE HONORABLE HOUSE OFREPRESENTATIVES,SPEAKER FELICIANOBELMONTE, CHAIRMAN NIELTUPAS, JR., COMMITTEE ON JUSTICE and theHONORABLE SENATE OF THEPHILIPPINES,

Respondents.x-------------------------------------

-----x

ATTY. OLIVER O. LOZANO OFTHE LAWYERS LEAGUE FORA BETTER PHILIPPINES ANDREV BERNARDO MAGNO OF JOHN 3:16 MINISTRYINTERNATIONAL,

Petitioners,

-versus-

SENATE OF THEPHILIPPINES, NIEL TUPAS, JR., REYNALDO UMALI, JOSEPH EMILIO ABAYA, ETAL.,

Respondents.x---------------------------------------x

VLADIMIR ALARIQUE T.CABIGAO,

Petitioner,

G.R. No. 199509

G.R. No. 199569

G.R. No. 199517

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-versus-

HOUSE OFREPRESENTATIVES andSENATE,

Respondents.x------------------------------------------x

HERMAN TIU LAUREL,RODOLFO S. SALANDANANand RUFINO U. MARTINEZ,

Petitioners,

-versus-

SENATE OF THE

PHILIPPINES, OFFICE OF THESENATE SECRETARY andHOUSE OFREPRESENTATIVES,

Respondents.x------------------------------------------x

G.R. No. 199924

CONSOLIDATED COMMENTAD CAUTELAM EX SUPERABUNDANTI

(WITH OPPOSITION TO THE APPLICATIONFOR A TEMPORARY RESTRAINING ORDER)

Respondents SENATE OF THE PHILIPPINES (Senate),

sitting as the Senate Impeachment Court (Impeachment

Court), and HOUSE OF REPRESENTATIVES (House), through

the Office of the Solicitor General (OSG), by way of special

appearance and in compliance with the Honorable Supreme

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Courts Resolution dated January 17, 2012, respectfully submit

this Consolidated Comment Ad Cautelam Ex Superabundanti

(With Opposition to the Application for a Temporary Restraining

Order).1

The Consolidated Petitions raises matters purely political in

character which may be decided or resolved only by the Senate

and the House. Hence, this Consolidated Comment Ad Cautelam

ExSuperabundanti is being filed by herein respondents without

submitting themselves to the jurisdiction of the Honorable

Supreme Court and without conceding the constitutional

and exclusive power of the House to initiate all cases of

impeachment and of the Senate to try and decide all cases

of impeachment.2

PRELIMINARY STATEMENT

The following consolidated petitions for certiorari and

prohibition under Rule 65 of the Rules of Court assail the

constitutionality and validity of the Verified Complaint for

Impeachment (Verified Impeachment Complaint) and the Articles

of Impeachment dated December 12, 2011 against the Honorable

Chief Justice Renato C. Corona (CJ Corona):

1 For more abundant caution (Blacks Law Dictionary, 9th ed. 2009).2 Constitution, Art. XI, Sec. 3 (6).

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1. Atty. Vicente D. Millora v. The Honorable Houseof Representatives, et al., G.R. No. 199535(Millora Petition);

2. Citizens Homobono A. Adaza and Alan Paguiav. House of Representatives, et al., G.R. No.199694 (Adaza Petition);

3. Danilo A. Lihaylihay v. The Honorable House ofRepresentatives, et al., G.R. No. 199569(Lihaylihay Petition);

4. Atty. Oliver Lozano of the Lawyers League forA Better Philippines, et al. v. Senate of thePhilippines, et al., G.R. No. 199569 (Lozano

Petition);

5. Vladimir Alarique T. Cabigao v. House ofRepresentatives et al., G.R. No. 199517(Cabigao Petition);3 and

6. Herman T. Laurel et al. v. Senate of thePhilippines, Office of the Senate Secretary andHouse of Representatives, G.R. No. 199924(Laurel Petition).

Petitioners therein pray for the issuance of a Temporary

Restraining Order (TRO) before hearing or to set an oral argument

for the purpose.4

STATEMENT OF THE CASE

On January 31, 2012, herein respondents received a copy of

the Resolution dated January 17, 2012 of the Honorable Supreme

Court requiring them to submit their Comment to the

Consolidated Petitions within ten (10) days from notice or until

February 10, 2012. In view of the significance, complexity of the

3 To date, respondents have not received a copy of the Cabigao Petition.4 Petitioners Adaza and Paguia have filed the following: (a) Urgent Motion to IssueRestraining Order Before Hearing or to Set an Oral Argument for That Purpose dated January10, 2012; and (b) Second Urgent Motion to Issue a Temporary Restraining Order BeforeHearing or to Set an Oral Argument for That Purpose dated January 13, 2012.

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issues involved and relation to G.R. No. 200242, entitled Chief

Justice Renato C. Corona vs. Senate of the Philippines, et al., and

G.R. No. 200238, entitled Philippine Savings Bank, et al. vs.

Senate Impeachment Court, respondents Senate and the

Prosecution Panel moved for a total of twenty (20) day extension

of the period, or until March 1, 2012, to file the required pleading.

This Consolidated Comment Ad Cautelam Ex Superabundanti is

being filed within the extended period prayed for.

COUNTERSTATEMENT OF FACTS

On December 12, 2011, one hundred eighty-eight (188)

Members of the House filed the Verified Impeachment Complaint5

against CJ Corona on the following grounds: (a) betrayal of public

trust; (b) culpable violation of the Constitution; and (c) graft and

corruption. In accordance with the Rules of Procedure in

Impeachment Proceedings (House Impeachment Rules),6

the

verification of the Verified Impeachment Complaint reads:

I/We, Members of the House of Representatives, of legal age, Filipinos, after beingsworn in accordance with law, do hereby depose andstate: That I/We are the Complainants in the above-entitled Complaint/Resolution of Impeachment; ThatI/We have caused the said Complaint/Resolution ofImpeachment; That I/We have caused the saidComplaint/Resolution to be prepared and I/We haveread the contents thereof; That the allegationstherein are true of our own knowledge and belief onthe basis of appreciation of documents and otherrecords pertinent thereto;

5 Annex A of the Adaza Petition.6 A certified true copy of the House Impeachment Rules is attached hereto as Annex 1.

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The Verified Complaint having been filed by at least one-

third of all House of Representatives Members (or by at least 95

congressmen and congresswomen), it automatically became the

Articles of Impeachment and, on December 13, 2011, was

immediately transmitted to the Senate in accordance with Section

13, Rule IV of the House Impeachment Rules.

On December 14, 2011, the Senate convened as an

Impeachment Court. Summons was then issued directing CJ

Corona to file his answer to the Articles of Impeachment within a

non-extendible period of ten (10) days from notice.7 CJ Corona

filed his Answer8 dated December 21, 2011.

On December 29, 2011, CJ Corona filed a Motion for

Preliminary Hearing9 praying that:

1. A preliminary hearing be held on theaffirmative defense that the verification of theVerified Complaint for Impeachment is fatallydefective; and

2. Thereafter, the Verified Complaint forImpeachment be dismissed.

7 A copy of the Summons issued by the Senate acting as an Impeachment Court is attachedhereto as Annex 2.8 A copy of CJ Coronas Answer dated December 21, 2011 is attached hereto as Annex 3.9 A copy of CJ Coronas Motion for Preliminary Hearing dated December 29, 2011 is attachedhereto as Annex 4.

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On January 16, 2012, the Senate Impeachment Court,

through Senate President and Presiding Officer Juan Ponce Enrile

(Sen. Enrile), denied CJ Coronas Motion for Preliminary Hearing

for lack of merit. The impeachment trial thereafter proceeded.

The impeachment trial of CJ Corona is now ongoing before the

Senate.

ARGUMENTS

I.

PETITIONERS HAVE NO LEGALSTANDING.

II.

CONGRESS HAS THE SOLE ANDEXCLUSIVE POWER TO INITIATE,TRY AND DECIDE IMPEACHMENTCASES.

III.

IN ANY EVENT, THEIMPEACHMENT COURT DID NOTCOMMIT ANY GRAVE ABUSE OFDISCRETION; IT HAS, IN FACT,BEEN CONDUCTING THEPROCEEDINGS JUDICIOUSLY.

IV.

SUBJECTING THE ON-GOINGIMPEACHMENT TRIAL TOJUDICIAL REVIEW DEFEATS THEVERY ESSENCE OFIMPEACHMENT.

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V.

THE VERIFIED IMPEACHMENTCOMPLAINT WAS FILED INACCORDANCE WITH THE 1987CONSTITUTION.

VI.

THE CASE HAS BECOME MOOTAND ACADEMIC.

DISCUSSION

I. PETITIONERS HAVE NO

LEGAL STANDING.

Petitioners, as citizens, taxpayers and lawyers, claim that

they should be allowed to actively participate in the discussion

and resolution of public issues which affect the future of the

country. They also claim that the House violated the Constitution

in impeaching CJ Corona. Claiming to be the representatives of

the general public, petitioners assert a public right in assailing the

alleged illegal official action of the respondents.

Locus standi or legal standing is defined as a personal and

substantial interest in the case such that the party has

sustained or will sustain direct injury as a result of the

governmental act that is being challenged. The gist of the

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question of standing is whether a party alleges such personal

stake in the outcome of the controversy as to assure that

concrete adverseness which sharpens the presentation of issues

upon which the court depends for illumination of difficult

constitutional questions.10

The following are the requirements before taxpayers, voters,

concerned citizens and legislators are given standing to sue: 1)

the cases involve constitutional issues; 2) for taxpayers, there

must be a claim of illegal disbursement of public funds or that the

tax measure is unconstitutional; 3) for voters, there must be a

showing of obvious interest in the validity of the election law in

question; 4) for concerned citizens, there must be a showing

that the issues raised are of transcendental importance which

must be settled early; and 5) for legislators, there must be a

claim that the official action complained of infringes upon their

prerogatives as legislators.11

Petitioners have no legal standing because they have not

sustained or will not sustain a direct personal injury should the

impeachment proceedings continue. Their interests are only

general and common to all members of the public.

10 Integrated Bar of the Philippines vs. Zamora, 338 SCRA 81 (2000), citing Joya vs.PCGG, 225 SCRA 568 (1993).11David vs. Macapagal-Arroyo, supra.

10
http://sc.judiciary.gov.ph/jurisprudence/2003/nov2003/..%5C..%5C2000%5Caug2000%5C141284.htmhttp://sc.judiciary.gov.ph/jurisprudence/2003/nov2003/..%5C..%5C2000%5Caug2000%5C141284.htm


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Petitioners cannot even pursue this case as taxpayers. They

failed to show any illegal disbursement of public funds, or that

public money is being wasted or deflected to any improper

purpose. The filing of the Verified Impeachment Complaint and

the impeachment trial is in accordance with the Houses exclusive

power to initiate all cases of impeachment and the Senates sole

power to try and decide all cases of impeachment.12

Petitioners cannot likewise claim to have legal standing as

lawyers. The mere invocation by any member of the legal

profession of the duty to preserve the law and nothing more,

although undoubtedly true, does not suffice to clothe him with

standing. His interest is too general and shared by other groups

and the whole citizenry.13

Finally, CJ Corona, the direct injured party in the

impeachment case sought to be voided, has already filed a

separate petition to question the validity of the impeachment

proceedings.14 There is, therefore, no reason why petitioners

should be allowed to separately question the impeachment

proceedings against CJ Corona.

12 Article XI, Section 3 (1) and (6) of the Constitution.13Francisco vs. House of Representatives, G.R. No. 160261, November 10, 2003.14 Chief Justice Renato C. Corona vs. Senate of the Philippines sitting as an ImpeachmentCourt, G.R. No. 200242.

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II. CONGRESS HAS THE SOLEAND EXCLUSIVE POWER TOINITIATE, TRY AND DECIDE

IMPEACHMENT CASES.

The Constitution confers upon Congress the sole and

exclusive authority to initiate, try and decide all cases of

impeachment, to wit:

(a) The House shall have the exclusive power

to initiate all cases of impeachment.15

(b) The Senate shall have the sole power totry and decide all cases of impeachment.16 (Emphasissupplied.)

The words sole and exclusive are of considerable

significance. Sole is defined as having no companion,

solitary, being the only one, and functioning independently

and without assistance or interference.17 The word exclusive,

on the other hand, is defined as shutting out all others from a part

or share.18

The use of the words sole and exclusive gives the House

the exclusive authority to initiate and the Senate the sole

authority to try and decide all cases of impeachment. It means

that they alone shall have the authority to determine the form,

manner and conduct by which an impeached public officer shall

be tried, and whether said public officer should be convicted or

15 Note 1, Supra, Article XI Section 3 (1).16Ibid. at (6).17 Websters Third New International Dictionary 2168 (1971), cited in Nixon vs. US, 5066U.S. 224 (1993).18 http://dictionary.reference.com/browse/exclusive.

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acquitted.19

There are three modes of initiating an impeachment case

under the Constitution. The first mode involves the filing of a

verified impeachment complaint by a Member of the House of

Representatives.20 The second mode involves the filing of a

verified impeachment complaint by a citizenupon a resolution of

endorsement by any Member of the House.21 In both these

modes, the verified impeachment complaint shall be referred to

the House Committee on Justice. After hearing and by a majority

vote of all its members, the House Committee on Justice shall

submit its report to the House, together with the corresponding

resolution.22 Thereafter, a vote of at least one-third (1/3) of all the

Members of the House shall be necessary either to affirm a

favorable resolution with the Articles of Impeachment of the

House Committee, or override its contrary resolution. The vote of

each Member shall be recorded.23 The third mode of initiating an

impeachment complaint involves the filing, by at least one-third

of all the Members of the House, of a verified impeachment

complaint or resolution of impeachment. Under this mode, the

verified impeachment complaint shall constitute the Articles of

Impeachment and trial by the Senate shall forthwith proceed.24

19Nixon vs. US, 5066 U.S. 224 (1993).20 1987 Constitution, Article XI, Section 3(2).21Ibid.22Ibid.23 1987 Constitution, Article XI, Section 3(3).24 1987 Constitution, Article XI, Section 3(6).

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The impeachment case against CJ Corona was initiated by the

House under the third mode.

The sole power to try and decide all cases of

impeachment, on the other hand, is limited only by three

very specific requirements. These are: (a) the Senators

shall be under oath or affirmation; (b) when the President

is on trial, the Chief Justice of the Supreme Court shall

preside (but not vote) over the impeachment trial; and (c)

the impeached public officer may only be convicted upon

the vote or agreement of two-thirds (2/3) of all the

Members of the Senate.25 These limitations are precise,

and their nature suggests that no additional limitations on

the form, manner and conduct of the impeachment trial

have been intended.26

a. Outside of any allegedtransgression of the expressconstitutional limitations, theimpeachment process wasnever intended by the Framersto be subject to judicial review.

Indeed, the Constitution gives the Honorable Supreme

Court expanded judicial power, which includes the duty to settle

actual controversies involving rights which are legally

25 1987 Constitution, Article XI, Section 3(6).26Nixon vs. US, 506 U.S. 224 (1993).

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demandable and enforceable, and to determine whether or not

there has been grave abuse of discretion amounting to lack or

excess of jurisdiction on the part of any branch or instrumentality

of the Government.27

The extent of the Supreme Courts power of expanded judicial

review in the context of impeachment proceedings,

however, was clarified by the Honorable Court in the twin cases of

Francisco vs. The House of Representatives28andGutierrez

vs. The House of Representatives.29 In these cases, the

Honorable Supreme Court maintained that, despite its

expanded certiorari jurisdiction, it cannot take cognizance

of purely political questions. Thus:

These petitions raise five substantial issues:

I. Whether the offenses alleged in theSecond impeachment complaintconstitute valid impeachable offenses

under the Constitution.

xxx

The first issue goes into the merits of thesecond impeachment complaint over which thisCourt has no jurisdiction. More importantly,any discussion of this issue would require thisCourt to make a determination of whatconstitutes an impeachable offense. Such adetermination is a purely political question

which the Constitution has left to the sounddiscretion of the legislation. Such an intent isclear from the deliberations of theConstitutional Commission.

27 Constitution, Article VIII, Section 1.28 G.R. No. 160261, November 10, 2003.29 G.R. No. 193459, February 15, 2011.

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Although Section 2 of Article XI of theConstitution enumerates six grounds forimpeachment, two of these, namely, other highcrimes and betrayal of public trust, elude a precise

definition. In fact, an examination of the records ofthe 1986 Constitutional Commission shows that theframers could find no better way to approximate theboundaries of betrayal of public trust and other highcrimes than by alluding to both positive and negativeexamples of both, without arriving at their clear cutdefinition or even a standard therefor.114 Clearly, theissue calls upon this court to decide a non-justiciablepolitical question which is beyond the scope of its

judicial power under Section 1, Article VIII. 30

(Emphasis and underscoring supplied.)

The Honorable Supreme Court in Francisco thereafter

defined what constitutes a political question which is beyond the

scope of its power of expanded judicial review:

In our jurisdiction, the determination of a trulypolitical question from a non-justiciable question liesin the answer to the question ofwhether there areconstitutionality imposed limits on powers orfunctions conferred upon political bodies. Ifthere are, then our courts are duty-bound to examinewhether the branch or instrumentality of thegovernment properly acted within such limits.31

(Emphasis supplied.)

Thus, to determine whether the case falls within the domain

of judicial review, the following issues must first be answered in

the affirmative:

(a) Whether a power or function has

been conferred upon a political body, branch

or instrumentality of government;

(b) Whether there are constitutionally

30Francisco, supra. See also Gutierrez, supra.31Francisco,supra.

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imposed limits on the said power or function;

and

(c) If there are limits, whether the

body, branch or instrumentality properly

acted within such limits.

This three-fold test was applied in Francisco and

Gutierrez. In Francisco, the Honorable Supreme Court

recognized the exclusive power of the House to initiate

impeachment cases and the express constitutional limitations

attached to said power. Applying the constitutional limitations on

the Houses exercise of its exclusive power to initiate

impeachment cases, the Honorable Supreme Court barred the

second impeachment complaint against then Chief Justice Davide

on the ground that the same violated paragraph 5, Section 3,

Article XI of the Constitution which expressly provides that no

impeachment proceedings shall be initiated against the same

official more than once within a period of one year. The

Honorable Supreme Court in said case, however, refrained

from ruling on the issue of what constitutes an

impeachable offense for lack of any express constitutional

limitations in relation thereto.32

In Gutierrez, the Honorable Supreme Court again had

32 460 Phil. 830 (2003).

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occasion to rule upon the validity of an impeachment complaint in

relation to the limitation on the power to initiate impeachment

cases found under paragraph 5, Section 3, Article XI of the

Constitution. In said case, the Honorable Supreme Court upheld

the validity of the simultaneous referral of two impeachment

complaints to the House Committee on Justice for appropriate

action. It however dismissed petitioner Gutierrezs claimed denial

of her right to due process on account of the delay in the

publication of the Impeachment Rules, ruling that inasmuch as

the Constitution did not prescribe any limitation on the

manner of promulgation, the Court is in no position to

dictate a mode of promulgation beyond the dictates of the

Constitution.33

It is clear from both Francisco and Gutierrez that there are

instances when the Honorable Supreme Courts power of

expanded judicial review may indeed be exercised within the

context of an impeachment proceeding, i.e. where there is a

clear transgression of an express constitutional limitation

on the sole and exclusive power of the Congress to

initiate, try and decide impeachment cases.

That is not the case here.

33 643 SCRA 198, 244 (2011).

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In these consolidated cases, petitioners question the

Members of the House of Representatives appreciation of facts,

wisdom of their decisions, the alleged lack of sworn undertaking,

the merits of the impeachable offenses, and manner and speed of

acting on a political measure, which delve into the sole

jurisdiction of the Legislative Branch. Verily, they are political

questions which may not be subject to judicial jurisdiction.34

It must be stressed that no less than CJ Corona himself

admitted in his answer that the Impeachment Complaint was

properly verified. In fact, CJ Corona is questioning only the alleged

lack of probable cause against him.

In any case, with the filing and transmittal of the Verified

Impeachment Complaint to the Senate, it is conclusively

presumed that all constitutional and legal requisites have been

complied with. In Arroyo vs. De Venecia,35 the Honorable Court

ruled that when Congress has acted in a matter clearly within its

power, it would be an unwarranted invasion of the independence

of the Legislative Department for the court to set aside such

action as void because it may think that Congress has

misconstrued or departed from its own rules of procedure.36

34 Cf. Manuel N. Mamba vs. Edgar L. Lara, G.R. No. 165109, December 14, 2009, citingCruz in Political Law, 1998 Ed., page 81, citing Taada vs. Cuenco, 103 Phil. 1051.35 G.R. No. 127255. August 14, 1997.36 Citing State v. Savings Bank, 79 Conn. 141, 64 Atl. 5, 9-10 (1906).

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Unlike Francisco and Gutierrez, the foregoing do not

concern, or allege any violation of, the express and

exclusive constitutional limitations on the sole power of

the Senate to try and decide impeachment cases. The

grounds raised by CJ Corona pertain to actions, orders and

prerogatives of the Congress in the course of impeachment

proceedings that are not covered by any definite constitutional

limitation. Following the principle in Francisco and Gutierrez, it

is most respectfully submitted that the Honorable Supreme Court

cannot exercise its power of expanded judicial review in this case.

This is not to say that the Senate is left without any

significant check for its exercise of the sole power to try and

decide impeachment cases. This check must, however, be

provided by the text of the Constitution itself. To quote United

States Supreme Court Chief Justice William Rehnquist in Nixon

vs. United States:

The Framers have anticipated this objection andcreated two constitutional safeguards to keep theSenate in check. The first safeguard is that thewhole of the impeachment power is dividedbetween the two legislative bodies, with theHouse given the right to accuse and the Senategiven the right to judge. This split of authorityavoids the inconvenience of making the same

persons both accusers and judges; and guardsagainst the danger of persecution from theprevalency of a factious spirit in either of thosebranches. The second safeguard is the two-thirds supermajority vote requirement.37

(Emphasis supplied.)

37Supra.

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The same principle applies in our jurisdiction. Here, the

Constitution entrusted the sole power to try and decide

impeachment cases to the Senate, subject only to three

express and exclusive constitutional limitations. To recall,

these limitations are: (a) the Senators shall be under oath or

affirmation; (b) when the President is on trial, the Chief Justice of

the Supreme Court shall preside (but not vote) over the

impeachment trial; and (c) the impeached public officer may only

be convicted upon the concurrence of two-thirds (2/3) of all the

Members of the Senate.38

Again, it is most respectfully submitted that the grounds

raised by petitioners do not concern any clear violation of the

foregoing constitutional limitations. There is no basis for the

exercise of the Honorable Supreme Courts power of expanded

judicial review in these consolidated cases.

b. Grave abuse of discretion is atool or standard for judicialreview; it cannot be applied toevaluate the actions of theImpeachment Court unrelated

to the express and exclusiveconstitutional limitations onthe exercise of itsimpeachment powers.

38 Constitution, Article XI, Section 3(6).

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If the framers intended to confine impeachment proceedings

to clear and simple judicial exercise, it could have easily done so.

They, however, saw it fit to exclude the Judiciary from the

adjudication of impeachments. This fact all the more underscores

the nature of impeachment as a political, rather than judicial,

process. At best, all that is being asked of the Senate, as the body

solely mandated by the Constitution to try and decide

impeachment cases, is that it be judicious. Judicious is defined as

well-considered, discreet, widely circumspect.39

Judicious - not judicial. The framers of theConstitution carefully excluded the judiciary (all butthe Chief Justice, who presides at the Senate trial ofan impeached President) from the adjudication of

impeachments.40

There are no other constitutionally provided standards by

which the Senate should try and decide impeachment cases.

Neither is there a constitutional requirement that the Senate

should conduct an impeachment trial like a criminal case, a civil

case or any other judicial proceeding. Such details, among others,

were left to the Senate to provide as public interests, changing

conditions and circumstances may require.41

For these reasons, it is respectfully submitted that the

concept of grave abuse of discretion cannot apply here. Grave

39 Blacks Law Dictionary, 9th ed. 2009.40 Posner, Richard A., An Affair of State, The Investigation, Impeachment, and Trial ofPresident Clinton, Harvard University Press, Second Printing Edition, 1999, p. 2.41Dillon v. Gloss, 256 U.S. 368, 376 (1921).

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abuse of discretion is essentially a tool or standard for judicial

review. This standard is not applicable when the controversy or

issue pertains to the exercise of powers solely vested by the

Constitution in a political body. This is precisely because by

vesting such powers solely with the Senate, the intention of the

Framers was not to subject the decision-making to any outside

review. Rather, the intention was to exclusively confine the same

with the Senate.

To illustrate, the Constitution vested the Honorable Supreme

Court with judicial power, that is, the duty to settle actual

controversies involving legally demandable and enforceable

rights, as well as determine whether a branch or instrumentality

of Government has committed grave abuse of discretion

amounting to lack or excess of jurisdiction. Pursuant to this

power, the Honorable Supreme Court, as the highest court of the

land, can resolve, with finality, actual controversies falling

within its jurisdiction. In so doing, it can never be accused of

having gravely abused its discretion.

The Senate, on the other hand, was vested by the

Constitution with the sole power to try and decide impeachment

cases. In the same way that it would be impossible under our

Constitution to accuse the highest court of the land to have

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gravely abused its discretion in deciding matters falling within its

jurisdiction, the Senate, absent any transgression of the three

express and constitutionally imposed restrictions of its power,

cannot be considered to have acted with grave abuse of

discretion in its conduct of an impeachment trial. To construe

otherwise would be an unjustified infringement of the Senates

sole constitutional power and duty to try and decide

impeachment cases.

III. IN ANY EVENT, THEIMPEACHMENT COURT DID NOTCOMMIT GRAVE ABUSE OFDISCRETION; IT HAS, IN FACT,

BEEN CONDUCTING THEPROCEEDINGS JUDICIOUSLY.

The Impeachment Courts conduct of its proceedings itself

belies any allegation of grave abuse of discretion.

Grave abuse of discretion has been defined as the

capricious and whimsical exercise of judgment, the exercise of

power in an arbitrary manner, where the abuse is so patent and

gross as to amount to an evasion of positive duty.42

Records of the proceedings before the Impeachment Court

show that the same have been conducted in accordance with the

42 Villarosa vs. House of Representatives Electoral Tribunal, G.R. Nos. 143351 and144129, September 14, 2000, 340 SCRA 396 as cited in Henry Jun Dueas vs. Houseof Representatives Electoral Tribunal, et al., G.R. No. 191550, May 4, 2010.

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Senate Rules of Procedure on Impeachment Trials, particularly

Rule VI of the said Rules which provides:

VI. The President of the Senate or the Chief Justicewhen presiding on the trial may rule on allquestions of evidence including, but not limitedto, questions of materiality, relevancy,competency or admissibility of evidence andincidental questions, which ruling shall stand asthe judgment of the Senate, unless a Member ofthe Senate shall ask that a formal vote be takenthereon, in which case it shall be submitted to theSenate for decision after one contrary view is

expressed; or the Presiding Officer may at his/heroption, in the first instance, submit any suchquestion to a vote of the Members of the Senate.xxx

The Impeachment Court, in fact, holds regular caucuses to

discuss and resolve, by majority vote, any objection of a Member

of the Senate to a ruling made by the Honorable Presiding Officer

Sen. Enrile. Clearly, the decisions of the Impeachment Court are

arrived at thoroughly, reasonably, judiciously and after due

consideration of all pertinent issues. They can hardly be

considered capricious, whimsical or arbitrary.

Regardless, petitioners allegations of grave abuse of

discretion must fail for utter lack of merit.

At the outset, it must be emphasized that CJ Corona has

submitted himself to the jurisdiction of the Impeachment Court.

He has filed his Answer, appeared on the first day of the trial

proper and has been actively participating in the trial through

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counsel. He even sought and obtained the following reliefs from

the Impeachment Court:

(1) CJ Coronas opposition to the request to

subpoena his wife and family was

granted by the Impeachment Court

when it refused to issue the requested

subpoena;

(2) CJ Coronas motion to exclude

presentation of evidence on Section 2.4

of the Articles of Impeachment was

granted;

(3) CJ Coronas motion to disallow the

presentation of Philippine Airlines

executive Enrique Javier was likewise

granted.

In this regard, it is respectfully submitted that CJ Corona is

already estopped from questioning the Impeachment Courts

jurisdiction on the ground of an alleged defect in the transmittal

of the Articles of Impeachment. Likewise, petitioners cannot

question the verification of the Impeachment Complaint and its

transmittal to the Senate.

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Necessarily, all issues related to the sufficiency of the

allegations in the Articles of Impeachment, the admissibility and

quantum of evidence required for conviction and the propriety of

the issuance of subpoenae for the production of evidence, should

be left to the sound discretion of the Impeachment Court,

considering that the same are political questions outside the

ambit of the Honorable Courts certiorari jurisdiction. To reiterate,

this rule is mandated by the Honorable Supreme Courts ruling in

Francisco and Gutierrez.

Inasmuch as the Honorable Supreme Court has no

jurisdiction to pass upon the sufficiency of the impeachment

complaint, it is most respectfully submitted that it cannot review

the evidence and the manner of its submission to the

Impeachment Court.

Impeachment is inarguably a political act exercised by the

Legislature, a political body elected by and directly accountable to

the people. This power is lodged in those who represent the

great body of the people, because the occasion for its exercise

will arise from acts of great injury to the community, and the

objects of it may be such as cannot easily be reached by an

ordinary tribunal.43

43 Labovitz, John R., Presidential Impeachment, 20 (1978) as cited in Concurring Opinion(Sereno, J.) in Gutierrez vs. House of Representatives Committee on Justice.

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Full discretion is vested in Congress, both the House and the

Senate, to determine whether or not an officer should be

impeached, subject only to constitutionally provided limits

provided under Section 3, Article XI of the Constitution.

Thus, all issues, matters or questions affecting,

relating or referring to, in connection with, or arising

from, the determination of what constitutes an

impeachable offense involve political questions, the

resolution of which are left to the wisdom of Congress.

These issues include, but are not limited to, the

sufficiency of the allegations in the Articles of

Impeachment, the materiality, relevance, competency,

admissibility and quantum of evidence required for

conviction, the propriety of the issuance of subpoenae for

the production of evidence and other incidental questions.

With utmost due respect, the Honorable Supreme Court

cannot give due course to these consolidated petitions without

contravening the Constitution. The function to initiate, try and

decide impeachment cases is solely vested in Congress.

The political character of the process is underscored by a degree

of imprecision in the offenses subject of impeachment, thus

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allowing Congress sufficient leeway to describe the acts as

impeachable or not.44

To give due course to these consolidated petitions and grant

petitioners injunctive relief would be tantamount to effectively

deciding the outcome of the impeachment case in gross

arrogation of an exclusive constitutional duty accorded to a

separate and independent branch of Government. This, the

Honorable Supreme Court simply cannot do.

IV. SUBJECTING THE

IMPEACHMENT PROCESS TOJUDICIAL REVIEW DEFEATS THEVERY ESSENCE OFIMPEACHMENT.

Impeachment by the Legislature as representatives of the

People is the only constitutional check on members of the

Honorable Supreme Court under our constitutional system.45

With utmost due respect, permitting judicial review over

impeachment matters unrelated to any of the express

constitutional limitations thereon is tantamount to installing the

Honorable Supreme Court as the final reviewing authority over a

process meant to check its own actions. Questions will necessarily

44 Concurring Opinion (Sereno, J.) in Gutierrez, supra.45Nixon v. US, supra.

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arise as to the integrity and independence of the Honorable

Supreme Court in deciding such matters, especially when the

same involves the head of the entire Judiciary, as in this case. A

decision by the Honorable Supreme Court under these

circumstances may be perceived to have been rendered with

partiality, and may not gain the trust of the People. Furthermore,

the Constitution provided impeachment as the only means to

review a class of impeachable officers. Subjecting the

impeachment process to judicial review by the Supreme Court will

give its Members an unfair advantage over the other groups of

impeachable officers. This absurd and expectedly self-defeating

situation surely could not have been intended by the Framers of

the Constitution. Concomitantly, and with all due respect, the

Senate, pursuant to its duty under the Constitution, cannot permit

such situation to occur.

V. THE VERIFIEDIMPEACHMENT COMPLAINTWAS FILED IN ACCORDANCEWITH THE 1987 CONSTITUTION.

It is respectfully submitted that the Verified Impeachment

Complaint was filed in accordance with the 1987 Constitution.

At the outset, and at the risk of being repetitive, it must be

pointed out that CJ Corona, the only party with direct and material

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interest in these consolidated cases, has admitted that the

Verified Impeachment Complaint is verified.46 In fact, he is

assailing the validity of the Verified Impeachment Complaint only

on the basis of lack of probable cause. In any case, the Verified

Impeachment Complaint complied with the requirements of the

1987 Constitution for its immediate transmittal to the Senate.

As the agency of Government vested with the exclusive

power to initiate all cases of impeachment,47 the House has the

corresponding exclusive power to promulgate its own rules of

procedure for this purpose.48 The House Impeachment Rules were

promulgated on August 3, 2010. Under Section 3(4), Article XI of

the 1987 Constitution and Rule II of the House Impeachment

Rules, impeachment may be initiated through a verified complaint

or resolution of impeachment filed by at least one-third (1/3) of all

Members of the House.

The impeachment of CJ Corona was initiated through the

filing of a verified complaint by at least one-third of all Members

of the House. Relevantly, Rule IV of the House Impeachment

Rules provides:

Endorsement of the Complaint/Resolution tothe Senate. - A verified complaint/resolution ofimpeachment filed by at least one-third (1/3) of allthe Members of the House shall constitute theArticles of Impeachment, and in this case the verified

46 CJ Coronas Petition (G.R. No. 200242), par. 24.47 Constiution, Art. XI, Sec. 3(1).48 Constitution, Art. XI, Sec. 3(8).

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complaint/resolution shall be endorsed to the Senatein the same manner as an approved bill of the House.

The complaint/resolution must, at the time of

filing, be verified and sworn to before the SecretaryGeneral by each of the Members constituting at leastone-third (1/3) of all Members of the House.

The contents of the verification shall be asfollows:

"We, after being sworn in accordance with law,depose and state: That we are thecomplainants in the above-entitledcomplaint/resolution of impeachment; that we

have caused the said complaint/resolution tobe prepared and have read the contentsthereof; and that the allegations therein aretrue of our own knowledge and belief on thebasis of our reading and appreciation ofdocuments and other records pertinentthereto.

___________________(Signature)

Paragraph 1 of the Joint Verification and Certification of the

Verified Impeachment Complaint states:

I/We, Members of the House of Representatives, of legal age, Filipinos, after beingsworn in accordance with law, do hereby depose andstate: That I/We are the Complainants in the above-

entitled Complaint/Resolution of Impeachment; ThatI/We have caused the said Complaint/Resolution ofImpeachment; That I/We have caused the saidComplaint/Resolution to be prepared and I/We haveread the contents thereof; That the allegationstherein are true of our own knowledge and belief onthe basis of appreciation of documents and otherrecords pertinent thereto;

Clearly, the verification executed by the one hundred eighty-

eight (188) signing House Members strictly conformed to the

requirement imposed by the House Impeachment Rules. The

wording of the Joint Verification and Certification even followed

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the form prescribed under the House Impeachment Rules

verbatim. On its face alone, the validity of the verification of the

Verified Impeachment Complaint cannot be denied.

More importantly, the Verified Impeachment Complaint was

verified and sworn before the House Secretary-General. The

Journal of the House taken on December 12, 201149 is instructive:

xxx

TO THE COMMITTEE ON RULES

ADDITIONAL REFERENCE OF BUSINESS

VERIFIED COMPLAINT FOR IMPEACHMENT

In the matter of the Impeachment of Renato C.

Corona as Chief Justice of the Supreme Court of thePhilippines by Representatives Tupas, Abaya,Tanada, Umali (R.), Bag-ao, et al.

REMARKS OF REP. GONZALES (N.)

At this point, Rep. Gonzales informed the Bodythat a verified complaint for impeachment was filedagainst Supreme Court Chief Justice Renato C.Corona by Reps. Niel C. Tupas, Jr., Lorenzo R. Tanada

III, Reynaldo V. Umali, Kaka J. Bag-ao, and severalothers. He then asked the Secretary General thenumber of Members of the House who had verifiedand swore to before her on said impeachmentcomplaint.

The Chair also asked for the total membershipof the House at Present.

In reply, Secretary General Marilyn B.Barua-Yap stated that the House has a total

membership of 284 Members at present, one-third of which is equivalent to 95 Members.She said that 188 Members had verified andswore before her on the impeachmentcomplaint against Chief Justice Corona.(Emphasis supplied.)

49 A certified copy of the Journal of the House dated December 12, 2011 is attached heretoas Annex 6.

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xxx

QUERY FROM THE CHAIR

Before the Body could act on the motion,the Chair inqured whether the SecretaryGeneral could attest to the fact that 188Members had individually sworn before her onthe verification of the particular Complaint, towhich the latter responded in the affirmative.She reiterated that the procedure that wasfollowed was pursuant to Section 13, Rule IV ofthe Rules on Impeachment. (Emphasis supplied.)

From the foregoing excerpt of the Journal, the House

Secretary-General attested that all one hundred eighty-eight

(188) Members of the House had verified and sworn before her on

the Verified Impeachment Complaint.

In Arroyo vs. De Venecia,50 the Honorable Supreme Court

rules that the Journal is regarded as conclusive with respect to

matters that are required by the Constitution to be recorded

therein. With respect to other matters, in the absence of evidence

to the contrary, the Journals have also been accorded conclusive

effect.

In United States vs. Pons,51 the Honorable Supreme Court

spoke of the imperatives of public policy for regarding the

Journals as public memorials of the most permanent character.

50Supra.51 34 Phil. 729, 735 (1916), quoting State ex rel. Herron vs. Smith, 44 Ohio 348 (1886).

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They should be public, because all are required to conform to

them. They should be permanent, that rights acquired today upon

the faith of what has been declared to be law shall not be

destroyed tomorrow, or at some remote period of time, by facts

resting only in the memory of individuals.

To stress, the power to initiate impeachment proceedings

and promulgate rules of procedure governing the same is

exclusively vested in the House. The House may, therefore,

legally prescribe the form and manner by which an impeachment

complaint shall be verified, especially as the Constitution is silent

on the nature and character of the verification requirement. For

this reason alone, petitioners cannot insist on the application of

verification as expressly provided in the Rules of Court.

In any event, the rules on verification under the Rules of

Court do not apply in impeachment proceedings. Section 4, Rule 1

of the Rules of Court states that the Rules of Court shall not

apply to election cases, land registration, cadastral, naturalization

and insolvency proceedings, and other cases not herein provided

for, except by analogy or in suppletory character and whenever

practicable and convenient. Since the House Impeachment Rules

already contain a specific provision on verification, the Rules of

Court cannot be suppletorily applied.

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Nonetheless, assuming for the sake of argument that the

rule on verification under the Rules of Court can be applied here,

jurisprudence holds that the verification requirement is

substantially met when the pleading is signed and sworn to by a

party who has sufficient knowledge and belief to swear to the

allegations therein. Such a verification is deemed a sufficient

assurance that the matters alleged in the petition have been

made in good faith or are true and correct, and not merely

speculative.52 The verification executed by the one hundred

eighty-eight (188) House Members who prepared and filed the

Verified Impeachment Complaint undeniably satisfies this

requirement.

Finally, petitioners contend that based on newspaper and

media accounts, the Members of the House who signed the

Verified Impeachment Complaint could not have verified the same

because they were not furnished with copies of the Verified

Impeachment Complaint. As such, it would have been impossible

for the signing House Members to have read the Verified

Impeachment Complaint. Unfortunately for petitioners, said

newspaper accounts are not competent and authentic evidence.

Since they are hearsay, they are inadmissible in evidence.53

52Prince Transport Inc. vs. Garcia, G.R. No. 167291, January 12, 2011.53Spouses Viloria vs. Continental Airlines,Inc. G.R. No. 188288, January 16, 2012.

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In fine, whether the signing House Members actually read

the Verified Impeachment Complaint necessitates a

determination of facts which the Honorable Court is not in a

position to properly undertake. The Honorable Supreme Court is

not a trier of facts, and is not the proper forum for the ventilation

and substantiation of these claims.54

All told, the Verified Impeachment Complaint was properly

filed and verified in accordance with the Constitution and the

House Impeachment Rules. If there are pleadings or submissions

which were not properly verified, these would be the Consolidated

Petitions, which contain allegations founded solely on multiple

hearsay evidence and not on personal knowledge or authentic

records.

IV. THE CASE HAS BECOMEMOOT AND ACADEMIC.

On January 16, 2012, the Senate, sitting as an Impeachment

Court and the sole and exclusive body empowered to try and

decide cases of impeachment, ruled with finality on the validity

of the Verified Impeachment Complaint and the Articles of

Impeachment when it denied CJ Coronas Motion for Preliminary

54Soriano et al. vs. Yuzon, G.R. No. 74910, August 10, 1988.

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Hearing. The validity of the verification of the Verified

Impeachment Complaint was even admitted by CJ Corona himself

in his own Petition.55 There is, therefore, no justiciable

controversy to speak of. This case has now been rendered moot

and academic.

Where the issues have become moot and academic, there is

no justiciable controversy, thereby rendering the resolution of

the same of no practical use or value.56

OPPOSITION TO THE APPLICATION FOR ATEMPORARY RESTRAINING ORDER

To be entitled to a temporary restraining order or a writ of

preliminary injunction, petitioners must show, with clear and

convincing evidence, that the following requisites are present: (a)

their right is clear and unmistakable; (b) the invasion of their right

sought to be protected is material and substantial; and (c) there is

an urgent and paramount necessity for the writ to prevent serious

damage.57

These requisites are not present.

55 See Note 35.56Carlos Baldo Jr., vs. COMELEC, G.R. No. 176135, June 16, 2009.57Boncodin vs. National Power Corp. Employees Consolidated Union, 503 SCRA 611(2006).

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First, petitioners have not alleged, much less proven, the

existence of any legal right on their part to the issuance of a

temporary restraining order or injunctive relief.

Second, the filing of the Verified Impeachment Complaint

and the continuation of the impeachment proceedings certainly

do not materially and substantially invade any legal right of

petitioners part. There can be no invasion of rights when there is

no right to speak of.

Third, there is no urgent and paramount necessity to prevent

serious damage. The validity of the Verified Impeachment

Complaint and the Articles of Impeachment has already been

resolved by the Senate as the sole and exclusive body tasked

under the Constitution to try and decide impeachment cases. It is

therefore incumbent upon the Honorable Supreme Court to

exercise judicial restraint and refrain from issuing any injunctive

relief with respect to the ongoing impeachment proceedings.

Verily, the injury being claimed by petitioners as allegedly

resulting from the subject impeachment proceedings has no

factual and legal basis. The continuation of the impeachment

proceedings against the Honorable CJ Corona will in fact

strengthen the Constitution and the institutions of the

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Government. Public office is a public trust. Public officers and

employees must at all times be accountable to the people, serve

them with utmost responsibility, integrity, loyalty, and efficiency,

act with patriotism and justice, and lead modest lives.58 The

impeachment proceedings, which was initiated and is being

conducted in accordance with the 1987 Constitution, simply aims

to enforce the principle of public accountability and ensure that

impeachable public officials answer for their transgressions. It will

help define the powers of the three major branches of the

Government and strengthen the principle of separation of powers

and the system of checks and balances.

PRAYER

WHEREFORE, it is respectfully prayed that the Consolidated

Petitions be dismissed for utter lack of merit.

Other reliefs just or equitable under the premises are

likewise prayed for ad cautelam ex superabundanti.

Makati City for Manila, February 24, 2012.

FRANCIS H. JARDELEZASolicitor GeneralRoll No. 25719

IBP (Lifetime) No. 00037, 1-18-93MCLE Exemption No. III-0008523

58 Constitution, Art. XI, Sec. 1.

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KARL B. MIRANDAAssistant Solicitor GeneralRoll No. 33306

IBP (Lifetime) No. 04423, 1-9-2003MCLE Exemption No. III-000370

MARSHA C. RECONSenior State Solicitor

(Officer-in-Charge, Felix Angelo Bautista Division)Roll No. 41169

IBP No. 883342, 01-10-2012MCLE Compliance No. III-0003832

NOEL CEZAR T. SEGOVIASenior State Solicitor

Roll No. 40524IBP No. 880248, 01-09-2012MCLE Compliance No. III-0003843

HILARION B. BUBANState SolicitorRoll No. 50397

IBP (Lifetime) No. 841400MCLE Compliance No. III-0003390

LESTER O. FIELAssociate Solicitor

Roll No. 51983IBP No. 858305, 03-15-2011

MCLE Compliance No. III-0003785

JASON T. LORENZOAssociate Solicitor

Roll No. 55864IBP No. 883037, 01-09-12

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JUDY A. LARDIZABALAssociate Solicitor

Roll No. 57090IBP No. 866385, 08-08-11


DENISE S. DYAssociate Solicitor

Roll No. 57316IBP (Lifetime) No. 010412, 01-11-12MCLE Compliance No. III-0011975

MICHAEL T. MACAPAGALAssociate Solicitor

Roll No. 57135IBP No. 879933, 01-06-12


RONALD JOHN B. DECANOAssociate Solicitor

Roll No. 58393

IBP No. 884741, 01-20-2012MCLE Compliance No. (Exempted-New Lawyer)

MARLON P. BOSANTOGAttorney II

Roll No. 59094IBP No. 887196, 01-20-2012

MCLE Compliance No. (Exempted-New Lawyer)

OFFICE OF THE SOLICITOR GENERAL134 Amorsolo St., Legaspi Village, Makati City

Tel. Nos. 818-6301 to 09 local 239, 238 and 237

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COPY FURNISHED: (by registered mail)

Atty. Homobono A. AdazaPetitioner in G.R. No. 199694Suites 209-210 Richmark Bldg.72 Mindanao Ave., Quezon City

Atty. Alan PaguiaPetitioner in G.R. No. 19969417 Dr. Lazcano Street, Quezon City

Atty. Vicente D. MilloraPetitioner in G.R. No. 199535Ground Floor, Manere Building IIINo. 41 V. Luna Avenue, Quezon City

Mr. Danilo A. LihaylihayPetitioner in G.R. No. 19950924-A Don Gregorio St., Don AntonioHeights Subdivision, Brgy. Holy SpiritCommonwealth Avenue, Quezon City

Atty. Oliver O. LozanoPetitioner in G.R. No. 199569Lawyers' League for a Better Philippines (LLBP)No. 8 Everlasting StreetRoxas District, Quezon City

Atty. Vladimir Alarique T. CabigaoPetitioner in G.R. No. 199517

Cabigao Law Office2507 Santo Nio St., PandacanManila

Rev. Bernardo MagnoJohn 3:16 Ministry InternationalPetitioner in G.R. No. 19956959 M. Reyes Street, Brgy. RosarioMontalban, Rizal

Hon. Juan Ponce EnrileSenate PresidentOffice of the Senate PresidentRm. 606, 6th Floor GSIS Bldg.Pasay City

Hon. Feliciano R. Belmonte

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SpeakerHon. Neil Tupas, Jr.House of Representatives

Batasan Hills, Quezon City

The Senate SecretarySenate of the PhilippinesRm. 606, 6th GSIS BuildingPasay City

The Secretary GeneralHouse of RepresentativesBatasan Hills, Quezon City

Atty. Maria Valentina S. Santana-CruzSenate Legal CounselSenate of the PhilippinesPasay City

Public Information OfficeSupreme Court

EXPLANATION

For lack of time and messengerial manpower, copies of theforegoing Consolidated Comment were served by registered mailrather than by the preferred mode of personal service.

RONALD JOHN B. DECANO

Associate Solicitor

44

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