Francisco v. House of Representatives (November ten, two thousand three)
Francisco v. House of Representatives (November ten, two thousand three)
Doctrine
The Supreme Court held that impeachment is not beyond judicial review when the Constitution itself imposes clear limits on Congress' impeachment power. In particular, the one-year bar in Article eleven, Section three, subsection five is enforceable by the Court, and an impeachment complaint is deemed initiated upon filing and referral to the House Committee on Justice, or upon filing by at least one-third of the House Members.
Facts
Facts
Several petitions were filed questioning the constitutionality of the second impeachment complaint against Chief Justice Hilario G. Davide, junior. The controversy arose after the House of Representatives had earlier adopted a resolution directing the Committee on Justice to investigate, in aid of legislation, the manner of disbursement and expenditure of the Judiciary Development Fund.
On June two, two thousand three, former President Joseph E. Estrada filed the first impeachment complaint against Chief Justice Davide and seven Associate Justices of the Supreme Court. The complaint was endorsed by several Members of the House and was referred to the House Committee on Justice on August five, two thousand three. The Committee later found the complaint sufficient in form but dismissed it for insufficiency in substance.
Four months and three weeks after the first complaint was filed, the second impeachment complaint was lodged on October twenty-three, two thousand three by Representatives Gilberto Teodoro junior and Felix William Fuentebella. Unlike the first complaint, the second was accompanied by a Resolution of Endorsement/Impeachment signed by at least one-third of the Members of the House of Representatives. Petitioners claimed that the filing of the second complaint violated the constitutional prohibition against initiating impeachment proceedings against the same official more than once within a period of one year.
The petitions also assailed portions of the House's Rules of Procedure in Impeachment Proceedings, particularly Sections sixteen and seventeen of Rule five, which treated impeachment as initiated only upon the Committee on Justice's finding of sufficiency of substance or upon action by the House plenary. Petitioners argued that these rules distorted the constitutional meaning of "initiate" and allowed Congress to evade the one-year bar. The House and Senate were asked to comment, while various intervenors and amici curiae joined the dispute, all emphasizing the significance of the constitutional questions involved.
The Court consolidated the petitions and, in the course of the proceedings, required the parties to maintain the status quo while oral arguments were held. The House argued that impeachment was an internal and political matter beyond judicial interference, while the Senate maintained that the petitions were premature because no Articles of Impeachment had yet been transmitted to it.