Case Digest: Francisco versus House of Representatives
Case Digest: Francisco versus House of Representatives
Facts
November twenty-eight, two thousand one: The House of Representatives of the twelfth Congress adopted the "Rules of Procedure in Impeachment Proceedings," which provided that impeachment is only "deemed initiated" upon a finding of sufficiency in substance by the Committee on Justice or a House vote.
July twenty-two, two thousand two: The House adopted a resolution to investigate the disbursement of the Judiciary Development Fund.
June two, two thousand three: Former President Joseph Estrada filed the first impeachment complaint against Chief Justice Hilario G. Davide, Junior and seven Associate Justices.
August five, two thousand three: This first complaint was referred to the House Committee on Justice.
October thirteen, two thousand three: The Committee ruled the first complaint was "sufficient in form".
October twenty-two, two thousand three: The Committee voted to dismiss the first complaint for being "insufficient in substance".
October twenty-three, two thousand three: A second impeachment complaint was filed by Representatives Gilberto Teodoro, Junior and Felix William Fuentebella against Chief Justice Davide, specifically regarding the Judiciary Development Fund.
October twenty-eight, two thousand three: Various petitions were filed with the Supreme Court arguing the second complaint violated the constitutional one-year bar against multiple impeachment proceedings.
Issue
Issue
Whether the second impeachment complaint filed on October twenty-three, two thousand three, violates the constitutional prohibition under Section three(5), Article eleven, which states that no impeachment proceedings shall be initiated against the same official more than once within a period of one year.
Ruling Yes.
Explanation: The Supreme Court ruled that the term "initiate" means to file the complaint and take initial action on it. The Court rejected the House's "legal fiction" that a proceeding is only initiated at a later stage of the process. Under a proper constitutional interpretation, a proceeding is initiated when a verified complaint is filed and referred to the Committee on Justice. Since the first complaint was filed in June and referred in August two thousand three, any subsequent complaint filed against the same official before August two thousand four is unconstitutional. Therefore, the second complaint filed in October two thousand three-only four months after the first-violates the one-year bar.