CASE DIGEST

ANGARA V. ELECTORAL COMMISSION

GR NO. L-45081
FACTS
Ynsua, a candidate vying for the Angara’s position filed his election protest before the Electoral
Commission. Angara sought to prohibit the Electoral Commission from taking further
cognizance of the Ynsua’s motion.
Angara argues, “the constitution excludes from the Commission’s jurisdiction the power to
regulate the proceedings of such election contests. Moreover, the Commission can regulate the
proceedings of election protests only if the National Assembly has not availed of its primary
power to regulate such proceedings.
Issue
Does the Electoral Commission have the power to promulgate rules notwithstanding the
resolution of the National Assembly?
Ruling
Yes.
The purpose of the creation of the Electoral Commission was to transfer in its totality all the
powers previously exercised by the Legislature in matters pertaining to contested elections of its
members, to an independent and impartial tribunal.
The petition for a writ of prohibition against the Electoral Commission is hereby denied, with
costs against the petitioner. So ordered.
We hold, therefore, that the Electoral Commission was acting within the legitimate exercise of its
constitutional prerogative in assuming to take cognizance of the protest filed by the respondent
Pedro Ynsua against the election of the herein petitioner Jose A. Angara, and that the resolution
of the National Assembly of December 3, 1935 can not in any manner toll the time for filing
protests against the elections, returns and qualifications of members of the National Assembly,
nor prevent the filing of a protest within such time as the rules of the Electoral Commission
might prescribe.
In view of the conclusion reached by us relative to the character of the Electoral Commission as
a constitutional creation and as to the scope and extent of its authority under the facts of the
present controversy, we deem it unnecessary to determine whether the Electoral Commission is
an inferior tribunal, corporation, board or person within the purview of sections 226 and 516 of
the Code of Civil Procedure.
CALTEX V PALOMAR
GR NO. L-19650
FACTS:
Caltex conceived a promotional scheme which will increase its patronage for oil products called
“Caltex Hooded Pump Contest.” The contest calls for participants to estimate the number of
liters a hooded gas pump at each Caltex station will dispense during a specified period. To
participate, entry forms are only needed which can be made available upon request at each
Caltex station. No fee is required to be paid nor purchase has to be made prior to participating.
Foreseeing the extensive use of mails to publicize the promotional scheme, Caltex made
representations with the postal authorities to secure advanced clearance for mailing. Caltex,
through its counsel, posited that the contest does not violate anti-lottery provisions of the Postal
Law. The Postmaster General Palomar declined the grant of the requested clearance. Caltex
sought a reconsideration. Palomar maintained that if the contest was pursued, a fraud order will
be issued against Caltex. Thus, this case at bar.
ISSUES:
1. Whether or not the petition states a sufficient cause of action for declaratory relief
2. Whether or not the proposed contest violates the Postal Law
RULINGS:
The Court held that the petition states a sufficient cause of action for declaratory relief since it
qualifies for the 4 requisites on invoking declaratory relief available to any person whose rights
are affected by a statute to determine any question of construction or validity. To the petitioner,
the construction hampers or disturbs its freedom to enhance its business while to the respondent,
suppression of the petitioner’s proposed contest believed to transgress the law he has sworn to
uphold and enforce is an unavoidable duty.
Likewise, using the rules of Statutory Construction in discovering the meaning and intention of
the authors in a case clouded with doubt as to its application, it was held that the promotional
scheme does not violate the Postal Law in that it does not entail lottery or gift enterprise. Using
the principle “noscitur a sociis’, the term under construction shall be understood by the words
preceding and following it. Thus, using the definitions of lottery and gift enterprise which both
has the requisites of prize, chance and consideration, the promo contest does not clearly violate
the Postal Law because of lack of consideration.
City of Baguio v. Marcos G.R. No. L-26100. February 28, 1969
Facts: In April 12, 1912, the director of lands in the CFI of Baguio INSTITUTED the reopening
of cadastral proceedings. In November 13, 1922, a decision was RENDERED. The land involved
was the Baguio Townsite which was declared public land. In July 25, 1961, Belong Lutes
petitioned to reopen the civil case on the following grounds: 1) he and his predecessors have
been in continuous possession and cultivation of the land since Spanish times; 2) his
predecessors were illiterate Igorots, thus, were not able to file their claim. On the contrary, F.
Joaquin Sr., F. Joaquin Jr., and Teresita Buchholz opposed Lutes’ reopening on the following
grounds: 1) the reopening was filed outside the 40-year period provided in RA 931; 2) the
petition to reopen the case was not published; and 3) as lessees of the land, they have standing on
the issue.
Issue: Whether or not the reopening of the peririon was filed outside the 40-year period provided
in RA 931, which was ENACTED on June 20, 1953
Ruling: The Supreme Court grabted the reopening of cadastral proceedings
Ratio: The title of RA 931 was “An Act to Authorize the Filing in Proper Court under Certain
Conditions, of Certain Claims of Title to Parcels of Land that have been Declared Public Land,
by Virtue of Judicial Decisions RENDERED within the 40 Years Next Preceding the Approval
of this Act.” Section 1 of the Act reads as “..in case such parcels of land, on account of their
failure to file such claims, have been, or about to be declared land of the public domain by virtue
of judicial proceedings INSTITUTED within the 40 years next preceding the approval of this
act.” If the title is to be followed, November 13, 1922 is the date which should be followed,
hence, would allow the reopening of the case. If Section 1 is to be followed, the date of the
institution of reopening of the case which was April 12, 1912, the petition would be invalid.
StatCon maxim: The title is an indispensable part of a statute, and what may inadequately be
omitted in the text may be supplied or remedied by its title.
DAVID, ET AL. VS. ARROYO, ET AL.
G.R. Nos. 171396, 171409, 171485, 171483, 171400, 171489 & 171424 May 3, 2006
TOPICS: Constitutional Law, PP 1017, Sec. 17, Article XII
FACTS:
Arroyo issued PP 1017 declaring a state of national emergency and call upon AFP and the to
prevent and suppress acts of terrorism and lawless violence in the country. Permits to hold rallies
issued earlier by the local governments were revoked. Rallyists were dispersed. The police
arrested petitioner David and Llamas without a warrant.
President Arroyo issued PP 1021 declaring that the state of national emergency has ceased to
exist. Petitioners filed petitions with the SC, impleading Arroyo, questioning the legality of the
proclamation.
ISSUE:
Whether or not Presidential Proclamation No. 1017 is unconstitutional?
RULING:
No. PP 1017 is constitutional insofar as it constitutes a call by the President for the AFP to
prevent or suppress lawless violence whenever becomes necessary as prescribe under Section 18,
Article VII of the Constitution. However, the SC ruled that under Section 17, Article XII of the
Constitution, the President, in the absence of legislative legislation, cannot take over privately-
owned public utility and private business affected with public interest. Therefore, the PP No.
1017 is only partly unconstitutional.
FRANCISCO I. CHAVEZ v. JUDICIAL AND BAR COUNCIL, GR No. 202242, 2012-07-17
Facts:
Does the first paragraph of Section 8, Article VIII of the 1987 Constitution allow more than one
(1) member of Congress to sit in the JBC? Is the practice of having two (2) representatives from
each house of Congress with one (1) vote each sanctioned by the Constitution?
In 1994, the composition of the JBC was substantially altered. Instead of having only seven (7)
members, an eighth (8th) member was added to the JBC as two (2) representatives from
Congress began sitting in the JBC - one from the House of Representatives... and one from the
Senate, with each having one-half (1/2) of a vote.[7] Then, curiously, the JBC En Banc, in
separate meetings held in 2000 and 2001, decided to allow the representatives from the Senate
and the House of Representatives one full vote... each.[8] At present, Senator Francis Joseph G.
Escudero and Congressman Niel C. Tupas, Jr. (respondents) simultaneously sit in the JBC as
representatives of the legislature.
petitioner has questioned in this petition,[9] setting forth the following
GROUNDS FOR ALLOWANCE OF THE PETITION
I
Article VIII, Section 8, Paragraph 1 is clear, definite and needs no interpretation in that the JBC
shall have only one representative from Congress.
II
The framers of the Constitution clearly envisioned, contemplated and decided on a JBC
composed of only seven (7) members.
III
Had the framers of the Constitution intended that the JBC composed of the one member from the
Senate and one member from the House of Representatives, they could have easily said so as
they did in the other provisions of the Constitution.
IV
The composition of the JBC providing for three ex- fficio members is purposely designed for a
balanced representation of each of the three branches of the government.
V
One of the two (2) members of the JBC from Congress has no right (not even ½ right) to sit in
the said constitutional body and perform the duties and functions of a member thereof.
VI
The JBC cannot conduct valid proceedings as its composition is illegal and unconstitutional
Through the Office of the Solicitor General (OSG), respondents defended their position as
members of the JBC in their Comment[13] filed on July 12, 2012. According to them, the crux of
the controversy is the phrase "a representative of
Congress."... the House of Representatives, without the Senate and vice-versa, is not
Congress.[16] Bicameralism, as the system of choice by the Framers, requires that both houses
exercise their respective powers in the performance of its mandated duty which is to legislate.
when Section 8(1), Article VIII of the Constitution speaks of "a representative... from Congress,"
it should mean one representative each from both Houses which comprise the entire Congress.
Tracing the subject provision's history, the respondents claim that when the JBC was established,
the Framers originally envisioned a unicameral legislative body, thereby allocating "a
representative of the National Assembly" to the JBC.
The phrase, however, was not modified to... aptly jive with the change to bicameralism... the
Court... views the petition as essentially an action for declaratory relief under Rule 63 of the
1997 Rules of Civil Procedure... the petition is also for prohibition under Rule 65 seeking to
enjoin
Congress from sending two (2) representatives with one (1) full vote each to the JBC.
Issues:
(1) Whether or not the conditions sine qua non for the exercise of the power of judicial review
have been met in this case; and
(2) Whether or not the current practice of the JBC to perform its functions with eight (8)
members, two (2) of whom are members of Congress, runs counter to the letter and spirit of the
1987 Constitution.
Ruling:
the determinants established in jurisprudence are attendant in this case: (1) the character of the
funds or other assets involved in the... case; (2) the presence of a clear case of disregard of a
constitutional or statutory prohibition by the public respondent agency or instrumentality of the
government; and (3) the lack of any other party with a more direct and specific interest in the
questions being... raised.
The allegations are substantiated by facts and, therefore, deserve an evaluation from the Court.
The Court... need not elaborate on the legal and societal ramifications of the issues raised. It
cannot be gainsaid that the JBC is a constitutional innovation crucial in the selection of the
magistrates in our judicial system.
From a simple reading of the above-quoted provision, it can readily be discerned that the
provision is clear and unambiguous. The first paragraph calls for the creation of a JBC and
places the same under the supervision of the Court.
the use of the singular letter "a" preceding "representative of Congress" is unequivocal and
leaves no room for any other construction.
It is indicative of what the members of the Constitutional Commission had in mind, that is,
Congress may... designate only one (1) representative to the JBC. Had it been the intention that
more than one (1) representative from the legislature would sit in the JBC, the Framers could
have, in no uncertain terms, so provided.
erba legis non est recedendum from... the words of a statute there should be no departure.
even if the Court should proceed to look into the minds of the members of the Constitutional
Commission, it is undeniable from the records thereof that it was intended that the JBC be
composed of seven (7) members only.
the Court takes the initiative to clarify that it is not in a position to determine as to who should
remain as the sole representative of Congress in the JBC. This is a matter beyond the province of
the Court and is best left to the determination of
Congress.
the remedy lies in the amendment of this constitutional provision. The courts merely give effect
to the lawgiver's intent.
WHEREFORE, the petition is GRANTED. The current numerical composition of the Judicial
and Bar Council IS declared UNCONSTITUTIONAL. The Judicial and Bar Council is hereby
enjoined to reconstitute itself so that only one ( 1) member of Congress will sit as a...
representative in its proceedings, in accordance with Section 8( 1 ), Article VIII of the 1987
Constitution.
Principles:
The Court considers this a constitutional issue that must be passed upon, lest a constitutional
process be plagued by misgivings, doubts and worse, mistrust. Hence, a citizen has a right to
bring this question to the Court, clothed with legal... standing and at the same time, armed with
issues of transcendental importance to society. The claim that the composition of the JBC is
illegal and unconstitutional is an object of concern, not just for a nominee to a judicial post, but
for all citizens who have the right to seek... judicial intervention for rectification of legal
blunders.