G.R. No. 193459 ; February 15, 2011
MA. MERCEDITAS N. GUTIERREZ, Petitioner, vs. THE HOUSE OF REPRESENTATIVES COMMITTEE ON JUSTICE, RISA HONTIVEROS-BARAQUEL, DANILO D. LIM, FELIPE PESTAÑO, EVELYN PESTAÑO, RENATO M. REYES, JR., SECRETARY GENERAL OF BAGONG ALYANSANG MAKABAYAN (BAYAN); MOTHER MARY JOHN MANANZAN, CO-CHAIRPERSON OF PAGBABAGO; DANILO RAMOS, SECRETARY-GENERAL OF KILUSANG MAGBUBUKID NG PILIPINAS (KMP); ATTY. EDRE OLALIA, ACTING SECRETARY GENERAL OF THE NATIONAL UNION OF PEOPLE’S LAWYERS (NUPL); FERDINAND R. GAITE, CHAIRPERSON, CONFEDERATION FOR UNITY, RECOGNITION AND ADVANCEMENT OF GOVERNMENT EMPLOYEES (COURAGE); and JAMES TERRY RIDON OF THE LEAGUE OF FILIPINO STUDENTS (LFS), Respondents. FELICIANO BELMONTE, JR., Respondent-Intervenor.

FACTS

The Ombudsman, Ma. Merceditas Gutierrez (petitioner), filed a petition for certiorari and prohibition challenging the Resolutions dated September 1 and 7, 2010, of the House of Representatives Committee on Justice (public respondent). Two impeachment complaints were filed against petitioner. The first, by the “Baraquel group” (Risa Hontiveros-Baraquel, Danilo Lim, and spouses Felipe and Evelyn Pestaño), was filed on July 22, 2010, before the opening of the 15th Congress on July 26, 2010, and was endorsed by Party-List Representatives. It was transmitted to the House Speaker on July 27, 2010, and included in the Order of Business. The second complaint, by the “Reyes group” (Renato Reyes, Jr., et al.), was filed on August 3, 2010, after the Congress opened, and was also endorsed by Party-List Representatives. On August 11, 2010, during its plenary session, the House of Representatives simultaneously referred both complaints to the Committee on Justice. The Committee, by Resolution dated September 1, 2010, found both complaints sufficient in form. On September 7, 2010, by another Resolution, it found the complaints sufficient in substance, alleging culpable violation of the Constitution and betrayal of public trust, and directed petitioner to file an answer. Petitioner attempted to file a motion for reconsideration of the September 1 Resolution, but the Committee refused to accept it as premature. On September 13, 2010, petitioner filed the present petition. The Supreme Court issued a status quo ante order and required comments.

ISSUE

Whether the Supreme Court may exercise judicial review over the actions of the House of Representatives Committee on Justice in impeachment proceedings, specifically regarding the simultaneous referral and consideration of two impeachment complaints filed within a one-year period.

RULING

Yes, the Supreme Court may exercise judicial review. The Court, citing Francisco, Jr. v. House of Representatives, debunked the argument that impeachment proceedings are purely political and beyond judicial review. While the U.S. Constitution grants the House “sole power of impeachment” without limitation, the Philippine Constitution, though vesting in the House the exclusive power to initiate impeachment cases, provides specific limitations in Section 3(2), (3), (4), and (5) of Article XI. These include the manner of filing, the required vote, and the one-year bar on impeaching the same official. These limitations provide “judicially discoverable standards” for determining the validity of the exercise of congressional discretion. The Court has a duty, under the expanded definition of judicial power, to correct any grave abuse of discretion by any government branch. The people expressed their will by instituting these constitutional safeguards, indicating that impeachment was not intended to be at the sole discretion of Congress. The Court has previously exercised judicial review over congressional actions in cases like Santiago v. Guingona, Jr., Tañada v. Angara, Bondoc v. Pineda, Coseteng v. Mitra, and Daza v. Singson. Therefore, the petition presents a justiciable controversy.