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Santiago v. Guingona

1) The Supreme Court assumed jurisdiction over a petition questioning which senator was the rightful minority leader, as it involved the interpretation of constitutional provisions regarding quorum requirements and the election of Senate officers. 2) While political questions are generally left to the legislative and executive branches, the Court ruled it had the authority to intervene when determining if those branches complied with constitutionally imposed limits on their powers. 3) The Court ultimately dismissed the petition and upheld Senator Guingona's position as minority leader, finding no constitutional or legal issues with how he was selected for the role.

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71 views2 pages

Santiago v. Guingona

1) The Supreme Court assumed jurisdiction over a petition questioning which senator was the rightful minority leader, as it involved the interpretation of constitutional provisions regarding quorum requirements and the election of Senate officers. 2) While political questions are generally left to the legislative and executive branches, the Court ruled it had the authority to intervene when determining if those branches complied with constitutionally imposed limits on their powers. 3) The Court ultimately dismissed the petition and upheld Senator Guingona's position as minority leader, finding no constitutional or legal issues with how he was selected for the role.

Uploaded by

Marlon Sevilla
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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Subject: Constitution

Topic: Judicial Review


Full Case: https://www.lawphil.net/judjuris/juri1998/nov1998/gr_134577_1998.html

SEN. MIRIAM DEFENSOR- SANTIAGO and SEN. FRANCISCO TATAD, petitioners,


Vs
SEN. TEOFISTO GUINGONA, JR., and SEN. MARCELO FERNAN, respondents
GR. No. 134577, November 18, 1998

FACTS:
 July 31, 1998, Santiago and Tatad instituted an original petition for quo warrranto under
Rule 66, Sec 5 Rules of Court to oust Guingona as minority leader and declare Tatad as
rightful minority leader.
 Upon election of Sen Ople as president pro tempore and Sen. Drilon as majority leader,
Sen. Tatad manifested that, with the agreement of Sen, Santiago, allegedly the only other
member of the minority, he was assuming the position of minority leader. He explained
that those who voted for Sen. Fernan comprised the majority, while only those who had
voted for him, the losing nominee, belong to the “minority”.

ISSUE:
1. W/N the court have jurisdiction over the petition.

RULING:
1. YES. The Court assumed jurisdiction: 1. In the light of subsequent events which
justify its intervention. 2. Because the resolution of the issue hinged on the
interpretation of the constitutional provision on the prescence of a quorum to hold a
session and therein elect a Senate President.
Based on the case of Avelino vs Cuenco, questions involving an interpretation or
application of the a provision of the Constitution or the law, including the rules of
either house of Congress. Within this scope falls the jurisdiction of the Court over
questions on the validity of legislative or executive acts that are political in nature,
whenever the tribunal “finds constitutionally imposed limits on powers or functions
conferred upon political bodies”.
Justice Feria in his concurring opinion: “…so as to establish in this country the
judicial supremacy, with the Supreme Court as the Final Arbiter, to see that no one
branch or agency of the gov’t transcends the Constitution, not only in justiceable but
political questions as well.

Justice Perfecto: Indeed there is no denying that the situation, as obtaining in the
upper chamber of Congress, is highly explosive. It had echoed in the House of
Representatives. It has already involved the President of the Philippines. The situation
has created a veritable national crisis, and it is apparent that solution cannot be
expected from any quarter other than this Supreme Court, upon which the hopes of
the people for an effective settlement are pinned. 15

This case raises vital constitutional questions which no one can settle or decide if
this Court should refuse to decide them.

The constitutional question of quorum should not be left unanswered.

Tanada vs Cueno:
Political question refers to those questions which, under the Constitution are to be
decided by the people in their sovereign capacity, or in regard which full
discretionary authority has been delegated to the legislative or executive branch of the
gov’t. It is concerned upon the wisdom, not the legality, of a particular measure.
The Court ruled that the validity of the selection of members of the Senate
Electoral Tribunal by the senators was not a political question. The choice of these
members did not depend on the Senate's "full discretionary authority," but was
subject to mandatory constitutional limitations. 20 Thus, the Court held that not only
was it clearly within its jurisdiction to pass upon the validity of the selection
proceedings, but it was also its duty to consider and determine the issue.
Lansang vs Garcia:
CJ Conception wrote that the court had authority to and should inquire into
existence the factual bases required by the Constitution for the suspension of the
privilege of the writ of habeas corpus… the function of the Court is merely to check-
not to supplant- the Executive, or to ascertain merely whether he has gone beyond the
constitutional limits of his jurisdiction, not to exercise the power vested in him or to
determine the wisdom of his act.

After a close perusal of the pleadings and a careful deliberation on the


arguments, pro and con, the Court finds that no constitutional or legal infirmity or
grave abuse of discretion attended the recognition of and the assumption into office
by Respondent Guingona as the Senate minority leader.

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