Case Digest – December 10, 2022

1. G.R. No. L-1612 February 26, 1948

JORGE B. VARGAS vs. EMILIO RILLORAZA, JOSE BERNABE, MANUEL ESCUDERO, Judges of the
People's Court, and THE SOLICITOR GENERAL OF THE PHILIPPINES

FACTS: Petitioner Vargas assailed the validity of Sec. 14 of the People's Court Act
(Commonwealth Act 682) which provided that the President could designate Judges of First
Instance, Judges-at-large of First Instance or Cadastral Judges to sit as substitute Justices of the
Supreme Court in treason cases without them necessarily having to possess the required
constitutional qualifications of a regular Supreme Court Justice , for the following reasons: a) It
provides for the qualifications of the members of the Supreme Court, other than those provided in
Sec. 6, Art. VIII of the Philippine Constitution; b) It authorizes the appointment of the members of
the Supreme Court who do not possess the qualifications set forth in Sec. 6, Art. VIII of the Philippine
Constitution; c) It removes from office the members of the Supreme Court by procedure other than
impeachment; and d) It create two Supreme Courts.

ISSUE: Whether Sec. 14 of People's Court Act (Commonwealth Act 682) is not unconstitutional.

RULING: No. Sec. 14 of People's Court Act (Commonwealth Act 682) is unconstitutional.

Article VIII, Sections 4 and 5, of the Constitution do not admit any composition of the Supreme
Court other than the Chief Justice and Associate Justices therein mentioned appointed as therein
provided. And the transgression is enhanced and aggravated where a majority of the members of
the Court — as in this case — are replaced by judges of first instance. It is distinctly another
Supreme Court in addition to this.

Section 1 of Article VIII of the Constitution provides: "The Judicial power shall be vested in one
Supreme Court and in such inferior courts as may be established by law.” This provision makes the
Supreme Court a constitutional organism, whose existence, constitution and organization are
provided in the fundamental law of the land, and said matter cannot be the subject of laws
enacted by the legislative power, unless expressly so authorized by the Constitution itself.
Otherwise, Congress will be in a position to change the composition and organization of the
Supreme Court by actually amending the corresponding constitutional provisions, and such thing
cannot be done without violating the fundamental law, as any amendment of the same to take
effect must be submitted to the sanction and approval of people represented by the body of the
national electorate. Grounds for disqualification added by Section 14 of People’s Court Act
(Commonwealth Act No. 682) to those already existing at the time of the adoption of the
Constitution and continued by it is not only arbitrary and irrational but positively violative of the
organic law.

CONCLUSION: It is declared and ordered: (a) that Section 14 of the People's Court Act is
unconstitutional in the respects specified in the body of the resolution; and (b) that this case be
dealt with henceforward in pursuance of and in harmony with the resolution.