(G.R. No. 170338 , December 23, 2008)
-Garcillano (in G.R. No. 170338) filed a Petitionfor Prohibition to restrain the HouseRepresentatives Committees from using thetape recordings of the "illegally obtained"wiretapped conversations in their committeereports and for any other purpose. He furtherimplored that the said recordings and anyreference thereto be ordered stricken off therecords of the inquiry, and the respondentHouse Committees directed to desist fromfurther using the recordings in any of theHouse proceedings.-Ranada and Agcaoili (in G.R. No. 179275),retired justices of the CA, filed a Petition forProhibition
to bar the Senate from conductingits scheduled legislative inquiry. They argued inthe main that the intended legislative inquiryviolates R.A. No. 4200 and Section 3, Article IIIof the Constitution.-Maj. Lindsay Rex Sagge
a member of theISAFP and one of the resource personssummoned by the Senate to appear and testifyat its hearings, moved to
in G.R. No. 179275.
While both petitions involve the "Hello Garci"recordings, they have different objectives–the
is poised at preventing the playing of thetapes in the House and their subsequentinclusion in the committee reports, and the
seeks to prohibit and stop the conductof the Senate inquiry on the wiretappedconversation.
(1)WON petitioners have legal standing.[YES](2)WON there is an actual case orcontroversy. [NO: against the House of Rep. YES: against the Senate]
Court dismisses the firstpetition
, G.R. No. 170338, and
, G.R. No. 179275.)
or locusstandi refers to a personal and substantialinterest in a case such that the party hassustained or will sustain direct injury becauseof the challenged governmental act x x x,"thus, generally, a party will be allowed tolitigate only when (1) he can show that he haspersonally suffered some actual or threatenedinjury because of the allegedly illegal conductof the government; (2) the injury is fairlytraceable to the challenged action; and (3) theinjury is likely to be redressed by a favorableaction.
: However,considering that
is a mereprocedural technicality, the Court, in recentcases, has
relaxed the stringent directinjury test
David v. Macapagal- Arroyo
articulates that a "
hasbeen observed, allowing ordinary citizens,members of Congress, and civic organizationsto prosecute actions involving theconstitutionality or validity of laws, regulationsand rulings.Garcillano = direct injury. Ranada and Agcaoili= concerned citizens, taxpayers, and membersof the IBP. Intervenor Sagge = alleges violationof his right to due process considering that heis summoned to attend the Senate hearingswithout being apprised not only of his rightstherein through the publication of the SenateRules of Procedure Governing Inquiries in Aid of Legislation, but also of the intended legislationwhich underpins the investigation. He furtherintervenes as a taxpayer bewailing the uselessand wasteful expenditure of public fundsinvolved in the conduct of the questionedhearings.Given that petitioners Ranada and Agcaoiliallege an interest in the execution of the lawsand that intervenor Sagge asserts hisconstitutional right to due process, they satisfythe requisite personal stake in the outcome of the controversy by merely being citizens of theRepublic.Likewise, a reading of the petition in G.R. No.179275 shows that the petitioners andintervenor Sagge advance constitutional issueswhich deserve the attention of this Court inview of their seriousness, novelty and weightas precedents. The issues are of
transcendental and paramountimportance
not only to the public but also tothe Bench and the Bar, and should be resolvedfor the guidance of all.
Thus, in the exercise of its sound discretionand given the
it has shown inprior cases climaxing in the more recent caseof
, the Court recognizes the legalstanding of petitioners Ranada and Agcaoiliand intervenor Sagge.
ACTUAL CASE OR CONTROVERSY
Versus House of RepresentativesCourt
dismisses G.R. No. 170338 for being
moot and academic
. Repeatedly stressed inour prior decisions is the principle that theexercise by this Court of
judicial power islimited to the determination andresolution of actual cases andcontroversies.
By actual cases, we meanexisting conflicts appropriate or ripe for judicialdetermination, not conjectural or anticipatory,for otherwise the decision of the Court willamount to an advisory opinion. The power of judicial inquiry does not extend to hypotheticalquestions because any attempt at abstractioncould only lead to dialectics and barren legalquestions and to sterile conclusions unrelatedto actualities. Neither will the Court determine