Constitutional Law one: Case Digests
Constitutional Law one: Case Digests
One. Macalintal versus COMELEC
The Doctrine: While Congress has the power to fix the date of elections, it cannot postpone them indefinitely or repeatedly without a compelling state interest. Postponement cannot be used to extend the terms of elective officials, as it bypasses the voters' right to choose their leaders at regular intervals.
The Facts: Congress enacted R.A. Number fifty-five, which moved the December twenty twenty-two Barangay and Sangguniang Kabataan Elections to October twenty twenty-three. The law also allowed sitting officials to remain in a "hold-over" capacity. Atty. Romulo Macalintal challenged the law, arguing that Congress had overstepped its authority by effectively extending the terms of office, a power that belongs to the people.
The Conflict: Congress passed a law to move the twenty twenty-two Barangay/SK elections to twenty twenty-three.
The Reason: They claimed the money (eight billion pesos) was needed for pandemic recovery.
The Argument: Atty. Macalintal sued, saying Congress can't just "extend" terms of sitting officials by moving the goalposts of an election.
The Issue: Does the legislative power to fix the date of elections include the power to postpone them and extend the terms of sitting officials?
The Ruling: The Supreme Court declared the law unconstitutional. It held that the right to vote includes the right to vote on time. The Court ruled that
"budgetary reasons" (i.e., reallocating funds to address the pandemic) are insufficient to justify infringing a fundamental right. Although the law was struck down, the Court allowed the October twenty twenty-three elections to proceed for practicality, but mandated that the next BSKE must strictly follow the three-year interval.
Two. Francisco versus House of Representatives
Two. Francisco versus House of Representatives
The Doctrine: The "One-Year Bar Rule" prevents the initiation of impeachment proceedings against the same official more than once within a period of one year. "Initiation" begins the moment a verified complaint is filed and referred to the proper committee.
The Facts: In two thousand three, a second impeachment complaint was filed against Chief Justice Hilario Davide Junior, just months after a first complaint had been filed and dismissed. The petitioners argued that this second complaint violated the Constitution's limit on the frequency of impeachment.
The Conflict: A second impeachment case was filed against Chief Justice Davide just months after the first one failed.
The Rule: The Constitution says you can only "initiate" impeachment once a year.
The Story: The Court had to decide if "initiation" means the filing of the complaint or the actual trial in the Senate.
The Issue: Is the filing of a second impeachment complaint within the same year a "political question" beyond judicial review, and does it violate the one-year bar?
The Ruling: The Court ruled that it was justiciable (not a political question) because the issue involved a clear violation of a constitutional limit. The Court held that the second complaint was unconstitutional because "initiation" does not mean the actual trial in the Senate; it starts at the House of Representatives. To allow multiple filings in a year would paralyze the government.