CONSTITUTIONAL LAW

1. Pormento vs. Estrada

G.R. No. 191988, August 31, 2010

CORONA, C.J.:

Facts: In the May 1998 elections, Joseph Estrada was elected President
of the Philippines. He sought to run again in the May 2010 elections.
Pormento opposed his candidacy, filing a petition for disqualification
based on the constitutional provision that "[t]he President shall not be
eligible for any reelection." The COMELEC dismissed the petition, and
Estrada participated in the 2010 elections, garnering the second-highest
number of votes.

Issue: Whether or not Estrada was disqualified from running for the
presidency in the May 2010 elections due to the constitutional
prohibition on reelection.

Ruling: No. The Supreme Court dismissed the petition, ruling that since
Estrada was not elected President a second time, the issue of his
disqualification was moot. There was no live controversy or legal
conflict for the Court to resolve, as one essential requirement for
judicial review—an actual case or controversy—was lacking. The Court
emphasized that it only adjudicates ongoing, real disputes, and any
discussion of Estrada's reelection would be hypothetical and
speculative.

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2. Macalintal vs. COMELEC

G.R. No. 157013, July 10, 2003

AUSTRIA-MARTINEZ, J.:

Facts:
In Macalintal v. Commission on Elections, Atty. Romulo B. Macalintal
challenged the constitutionality of certain provisions of Republic Act
No. 9189, the Overseas Absentee Voting Act of 2003. The law established
a system for voting by Filipinos abroad. Macalintal argued that it
violated the 1987 Constitution, especially regarding the residency
requirement and the independence of the Commission on Elections
(COMELEC).
Issue:
Whether or not Section 5(d) of R.A. No. 9189 violates the residency
requirement in the Constitution.
Whether or not Section 18.5 empowers COMELEC to proclaim winners for
President and Vice-President, violating the constitutional mandate that
Congress does this.
Whether or not Sections 19 and 25 unduly interfere with COMELEC's
independence.
Ruling:
The Supreme Court ruled that Section 5(d) is constitutional, allowing
overseas voters to register while maintaining their residency. It
declared Section 18.5 unconstitutional, asserting that the power to
proclaim Presidential candidates lies with Congress. Sections 19 and 25
were also ruled unconstitutional for infringing on COMELEC's
independence, as they subjected its rules to Congressional review,
undermining its constitutional authority.

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3. Pimentel vs. Joint Canvassing Committee

G.R. No. 163783. June 22, 2004

Facts: Senator Aquilino Q. Pimentel, Jr. filed a petition seeking to

declare null and void the continued operation of the Joint Committee of
Congress tasked with canvassing votes for the President and Vice
President in the May 10, 2004 elections. Pimentel argued that the Joint
Committee ceased to exist following the adjournment sine die of Congress
on June 11, 2004. He claimed that all pending matters, including the
canvassing of votes, should terminate with the adjournment of the 12th
Congress, as the term of Congress had expired.
Issue: Whether or not the Joint Committee of Congress can continue its
functions after the adjournment sine die of Congress.
Ruling: No, the adjournment sine die of Congress does not terminate the
non-legislative functions of the 12th Congress, including its role as
the National Board of Canvassers. The Supreme Court ruled that while the
legislative functions of Congress ended with the adjournment, its non-
legislative duties, such as canvassing votes and proclaiming the
President and Vice President, continue until completed. Therefore, the
Joint Committee's existence and its work are constitutional and valid,
and the petition was dismissed.

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4. Macalintal vs. PET

G.R. No. 191618, November 23, 2010

NACHURA, J.:

Facts: Atty. Romulo Macalintal filed a motion for reconsideration

challenging the constitutionality of the Presidential Electoral Tribunal
(PET). He argued that the creation of the PET by the Supreme Court (SC)
does not fall within the scope of Section 4, Article VII of the 1987
Constitution, which pertains to the Executive Department. Additionally,
he claimed that PET exercises quasi-judicial powers, thus violating
Section 12, Article VIII of the 1987 Constitution.
Issue: Whether or not the Presidential Electoral Tribunal (PET) is
constitutional.
Ruling: Yes, the PET is constitutional. The Supreme Court held that the
exclusive authority granted to it to resolve issues related to the
election of the President and Vice President does not violate the
separation of powers between the judiciary and the executive. Election
disputes are adversarial in nature and involve justiciable questions,
fitting within the judiciary's scope. The creation of the PET was seen
as a necessary means to implement the SC's constitutional mandate under
Section 4, Article VII, making it an independent yet integral part of
the judiciary. Therefore, the PET's constitutionality was upheld, and
Macalintal's motion was denied.

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5. Soliven vs. Makasiar

G.R. No. 82585 November 14, 1988

PER CURIAM:

Facts: Journalist Louie Beltran, along with others, was charged with
libel by President Corazon Aquino after publishing defamatory
statements against her. President Aquino personally filed a
complaint-affidavit. Justice Makasiar argued that the President could
not file a complaint because doing so would compromise her immunity
from suit. He contended that if the President sued someone, she would
submit to the court’s jurisdiction and allow herself to be sued in
return, which could interfere with her duties.
Issue: Whether or not presidential immunity can be invoked by a
person other than the President, such as Beltran.
Ruling: No, presidential immunity cannot be invoked by someone other
than the President. The Supreme Court ruled that the privilege of
immunity from suit is exclusively granted to the President to ensure
the unimpeded performance of her duties. However, this immunity can
only be invoked by the President herself. It cannot be used by third
parties like Beltran as a defense in criminal cases. Additionally,
the President may choose to waive this immunity and submit to the
court’s jurisdiction if she so desires, but this decision rests
solely with the President.

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6. Estrada vs. Desierto

7. G.R. No. 146710-15, March 2, 2001
PUNO, J.:

Facts: The case arises from the events surrounding the ouster of
President Joseph Estrada during EDSA II. Estrada faced impeachment for
corruption allegations, particularly his involvement in the "jueteng"
scandal. However, the Senate impeachment trial collapsed after the
refusal to open key evidence, leading to mass protests. On January 19,
2001, military and police forces, along with members of Estrada’s
Cabinet, withdrew their support, prompting Estrada to leave Malacañang.
Gloria Macapagal-Arroyo was sworn in as president. Subsequently, Estrada
faced criminal charges, including plunder, before the Ombudsman. Estrada
argued that he should not be prosecuted, invoking presidential immunity
from suit.
Issue: Whether or not petitioner Estrada enjoys immunity from suit after
his presidency.
Ruling: No, petitioner Estrada does not enjoy immunity from suit after
his presidency. The Supreme Court held that presidential immunity only
applies to the sitting president, and Estrada, having vacated the
office, cannot invoke such immunity. The crimes he was charged with,
such as plunder and graft, cannot be shielded by immunity, as this
protection is not intended to cover illegal acts. Furthermore, Estrada’s
argument that he must first be convicted in an impeachment trial before
facing criminal prosecution was rejected, as the impeachment process was
already rendered moot by his resignation. Thus, Estrada is subject to
prosecution for his actions during his presidency.

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7 Gloria vs. CA
G.R. No. 119903, August 15, 2000

PURISIMA, J.:
Facts: Dr. Bienvenido Icasiano was appointed as the Schools Division
Superintendent of Quezon City by President Corazon Aquino on June 29,
1989. On October 10, 1994, Secretary Gloria recommended his reassignment
to the Marikina Institute of Science and Technology (MIST) following the
retirement of its superintendent. Although President Fidel Ramos
approved the reassignment, Dr. Icasiano requested reconsideration, which
Secretary Gloria denied. Subsequently, Dr. Icasiano sought a Temporary
Restraining Order (TRO) from the Court of Appeals, which was initially
denied but later granted, restraining the petitioners from implementing
the reassignment.
Issue: Whether or not the reassignment of Dr. Icasiano is only
temporary, thus exempting it from the doctrine established in Bentain
vs. Court of Appeals.
Ruling: No, the Supreme Court upheld the Court of Appeals' finding that
the reassignment was not merely temporary and was, therefore, subject to
the Bentain doctrine. The Court noted that the reassignment appeared
indefinite, as evidenced by Secretary Gloria's memorandum, which
emphasized Dr. Icasiano's qualifications for the new role without
specifying a time limit. The absence of a defined duration indicated an
intention to reassign him indefinitely, violating his security of
tenure. Thus, the reassignment constituted a constructive removal from
service rather than a legitimate temporary transfer.

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8 Rodriguez v. GMA
G.R. No. 119903August 15, 2000

PURISIMA, J.:

Facts: The case involves Rodriguez, a member of a peasant organization

in Cagayan Valley, who filed a petition for a Writ of Amparo and Writ of
Habeas Data against then-President Gloria Macapagal Arroyo and others.
He alleged that he was abducted, tortured, and released by the 17th
Infantry Battalion of the Philippine Army. During the legal proceedings,
the Court of Appeals was petitioned by Rodriguez for various reliefs,
including a temporary protection order, which was denied. The Court of
Appeals also dismissed Arroyo as a respondent, citing presidential
immunity from suit during her tenure.
Issue: Whether or not former President Arroyo should be dropped as a
respondent based on presidential immunity from suit.
Ruling: No, the Supreme Court held that former President Arroyo should
not be dismissed as a respondent on the basis of presidential immunity
from suit. The Court clarified that this immunity is available only to
sitting Presidents and does not extend to former Presidents. Arroyo, no
longer being in office, could not invoke this immunity to avoid
accountability for her actions related to Rodriguez's abduction. The
Court emphasized that the privilege of presidential immunity should not
obstruct the pursuit of truth or the vindication of rights, stating that
a non-sitting President is not shielded from legal scrutiny for acts
committed during their term. Additionally, the Court distinguished
between "term" and "tenure," asserting that immunity applies solely
during a President's actual incumbency, thereby allowing for judicial
examination of former officials’ actions.

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9 Senate vs. Ermita

G.R. No. 169777, April 20, 2006

CARPIO MORALES, J.:

Facts: The Senate Committee issued invitations to various Executive

Department officials to attend a public hearing regarding the North
Luzon Railways Corporation project with the China National
Machinery and Equipment Group. In response, President Gloria
Macapagal Arroyo issued Executive Order 464 on September 28, 2005,
which aimed to uphold the principle of separation of powers and
establish guidelines for executive privilege in legislative
inquiries.

Issue: Whether or not E.O. 464 contravenes the power of inquiry

vested in Congress.

Ruling: Yes, the Supreme Court held that E.O. 464 contravenes
Congress's power of inquiry. The Court emphasized that Congress has
an express constitutional right to conduct inquiries to aid
legislation, which includes obtaining information from the
executive branch. E.O. 464's provisions allowed the executive
branch to withhold information without clearly asserting a legal
right to do so or providing justifications, thus undermining
Congress's inquiry power. The Court declared Sections 2(b) and 3 of
E.O. 464 void, as they obstructed legislative inquiries, while
affirming the validity of Sections 1 and 2(a). The decision
reinforced the principle that government operations must be subject
to public scrutiny, reflecting the doctrine of popular sovereignty
and the public's right to participate in governance.

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10. Chavez vs. PEA

GR NO. 133250 July 9, 2002

CARPIO, J.:

Facts: On November 20, 1973, the government entered into a contract with
the Construction and Development Corporation of the Philippines (CDCP)
to reclaim portions of Manila Bay and construct the Manila-Cavite
Coastal Road. In 1977, President Marcos established the Public Estates
Authority (PEA) through Presidential Decree No. 1084, assigning it the
task of land reclamation and development. Subsequently, PEA took over
lands reclaimed under the Manila-Cavite Coastal Road and Reclamation
Project. On April 25, 1995, PEA entered into a Joint Venture Agreement
(JVA) with AMARI Coastal Bay Development Corporation to develop the
Freedom Islands and reclaim additional submerged areas. The Senate later
condemned the JVA as illegal, asserting that the reclaimed lands were
public domain and could not be alienated. Despite this, a Legal Task
Force upheld the JVA's legality. In 1998, petitioner Francisco I. Chavez
filed a petition to compel PEA to disclose the terms of the JVA, arguing
that the sale to AMARI violated the 1987 Constitution by attempting to
alienate public lands.

Issue: Whether or not the stipulations in the amended joint venture

agreement for the transfer of certain reclaimed lands to AMARI violate
the 1987 Constitution.

Ruling: Yes, the Court ruled that the stipulations in the amended JVA
violated the 1987 Constitution. The Court exercised its jurisdiction
despite arguments regarding judicial hierarchy and the exhaustion of
administrative remedies, as the case involved significant constitutional
issues. The PEA had a legal obligation to conduct public bidding for the
sale of government lands, which it failed to do. Furthermore, the
Regalian Doctrine was cited, affirming that all lands of the public
domain, including reclaimed areas, belong to the State and cannot be
alienated unless classified as agricultural. The Court emphasized the
need for proper legal classification before transferring ownership of
such lands, thus validating Chavez's standing as a taxpayer and
reinforcing the constitutional rights to public information and the
equitable distribution of natural resources.

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11. Chavez vs. PCGG

GR NO. 130716 December 9, 1998

PANGANIBAN, J.:

Facts:
Francisco I. Chavez, a taxpayer and former government official, demanded
that the Presidential Commission on Good Government (PCGG) disclose all
negotiations and agreements related to recovering the Marcoses' ill-
gotten wealth, asserting that this involves matters of paramount public
interest. The PCGG argued that Chavez's request was premature since the
agreements were not yet effective and binding, claiming that there was
no formal request for disclosure from Chavez.
Issues:
Whether or not the PCGG may be compelled to disclose to the public the
details of any agreement with the Marcoses.
Ruling:
Yes. The Supreme Court held that the right to information is not limited
to consummated transactions; it also extends to the exploratory stages
of such transactions. The Court found no specific laws limiting the
exercise of this right or the state's duty to disclose information. The
Court emphasized that the PCGG and its officials must provide sufficient
public information regarding any proposed settlements concerning ill-
gotten wealth, as these matters are of significant public concern.
Principle Applied:
The right to information includes both the exploratory stages and
consummated transactions, reflecting the broader principle that citizens
have a right to access information regarding government activities,
especially when it pertains to public interest. The ruling underscores
the accountability of government agencies to disclose information that
affects the public, in line with the constitutional guarantee of access
to information on matters of public concern.

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