San Beda College of Law – AlabangConstitutional Law 2 Case Digests

THE NATURE OF THE CONSTITUTION AND ITS RELATION WITH THE COURTS FRANCISCO VS. HOUSE OF
REPRESENTATIVES

[415 SCRA 44; G.R. No. 160261; 10 Nov 2003]

Facts:

Impeachment proceedings were filed against Supreme Court Chief Justice HilarioDavide.The justiciable
controversy poised in front of the Court was the constitutionalityof the subsequent filing of a second
complaint to controvert the rules of impeachmentprovided for by law.

Issue:

Whether or Not the filing of the second impeachment complaint against Chief JusticeHilario G. Davide,
Jr. with the House of Representatives falls within the one year barprovided in the Constitution and
whether the resolution thereof is a political question –has resulted in a political crisis.

Held:

In any event, it is with the absolute certainty that our Constitution is sufficient to addressall the issues
which this controversy spawns that this Court unequivocally pronounces,at the first instance, that the
feared resort to extra-constitutional methods of resolving itis neither necessary nor legally permissible.
Both its resolution and protection of thepublic interest lie in adherence to, not departure from, the
Constitution.In passing over the complex issues arising from the controversy, this Court is evermindful of
the essential truth that the inviolate doctrine of separation of powers amongthe legislative, executive or
judicial branches of government by no means prescribes forabsolute autonomy in the discharge by each
of that part of the governmental powerassigned to it by the sovereign people.At the same time, the
corollary doctrine of checks and balances which has beencarefully calibrated by the Constitution to
temper the official acts of each of these threebranches must be given effect without destroying their
indispensable co-equality.Thereexists no constitutional basis for the contention that the exercise of
judicial review overimpeachment proceedings would upset the system of checks and balances. Verily,
theConstitution is to be interpreted as a whole and "one section is not to be allowed todefeat another."
Both are integral components of the calibrated system of independenceand interdependence that
insures that no branch of government act beyond the powersassigned to it by the Constitution.When
suing as acitizen, the interest of the petitioner assailing the constitutionality of astatute must be direct
and personal. He must be able to show, not only that the law orany government act is invalid, but also
that he sustained or is in imminent danger ofsustaining some direct injury as a result of its enforcement,
and not merely that hesuffers thereby in some indefinite way. It must appear that the person
complaining hasbeen or is about to be denied some right or privilege to which he is lawfully entitled or