Santiago vs. Guingona
Santiago vs. Guingona
Facts:
On July 27, 1998, the first regular session of the eleventh Congress was held, with Sen.
John Henry R. Osmena as presiding officer. On the agenda for the day was election of
officers. The nominees for the position for Senate President was Se. Marcelo B. Fernan
and Sen. Francisco S. Tatad. By a vote of 20 to 2, Senator Fernan was declared the
duly elected President of the Senate.
On July 30, 1998, the majority leader informed the body chat he was in receipt of a
letter signed by the seven Lakas-NUCD-UMDP senators,9 stating that they had elected
Senator Guingona as the minority leader. By virtue thereof, the Senate President
formally recognized Senator Guingona as the minority leader of the Senate.
The following day, Senators Santiago and Tatad filed before this Court the subject
petition for quo warranto, alleging in the main that Senator Guingona had been
usurping, unlawfully holding and exercising the position of Senate minority leader, a
position that, according to them, rightfully belonged to Senator Tatad.
Issues:
Rulings:
No, the Court has no jurisdiction over the petition as there is no express provision in the
Constitution as to how both Houses elects the positions other the Senate President and
Theresa T. Godinez Constitutional 1 (Weekdays)
the House as stated in Art. 6, Sec. 16 states, “The Senate shall elect its President and
the House of Representatives, its Speaker, by a majority vote of all its respective
Members.” It further added the clause “Each House shall choose such other officers as
it may deem necessary” meaning, in this case, when the majority is reached with regard
to the election of the Senate President, the Senate rules now govern as to how the
other officers are posted.
Under these circumstances, we believe that the Senate President cannot be accused of
capricious or whimsical exercise of judgment or of an arbitrary and despotic manner by
reason of passion or hostility. Where no provision of the Constitution, the laws or even
the rules of the Senate has been clearly shown to have been violated, disregarded or
overlooked, grave abuse of discretion cannot be imputed to Senate officials for acts
done within their competence and authority.