G.R. No. L-71908 February 4, 1986
ALBERTO G. ROMULO, ET AL., petitioners, vs. HON. NICANOR E. YÑIGUEZ, ET AL., respondents.

FACTS

Petitioners, constituting more than one-fifth of the Batasang Pambansa members, filed on August 13, 1985, Resolution No. 644 with a verified complaint for the impeachment of President Ferdinand E. Marcos. The Speaker referred the resolution and complaint to the Committee on Justice, Human Rights and Good Government. The Committee, on the following day, August 14, 1985, found the complaint insufficient in form and substance, disapproved the resolution, dismissed all charges, and submitted its report. The Batasan noted the report and sent it to the archives. A subsequent motion to recall the resolution from the archives was disapproved.
On September 7, 1985, petitioners filed this petition for prohibition and mandamus. They sought to declare unconstitutional Sections 4, 5, 6, and 8 of the Batasan Rules of Procedure in Impeachment Proceedings, and to nullify the Committee Report dismissing the impeachment complaint. They prayed for writs to restrain enforcement of the cited rules and to compel the Committee to recall and report out the resolution and complaint for a trial by the Batasan as a body.

ISSUE

Whether the Supreme Court can review and nullify the Batasan Committee’s dismissal of an impeachment complaint and declare specific provisions of the Batasan’s impeachment rules unconstitutional.

RULING

The Supreme Court DISMISSED the petition for lack of merit. The Court held that the impeachment power is exclusively vested in the Batasang Pambansa under the 1973 Constitution. The Committee’s action in dismissing the complaint for insufficiency in form and substance involves a political question beyond judicial review. The Constitution only requires a vote of at least one-fifth of all members to initiate impeachment and a two-thirds vote to convict; it does not prescribe the detailed procedure, leaving this to the Batasan to determine through its own rules.
The Court emphasized the doctrine of separation of powers, albeit in a modified form under the parliamentary system. The interpretation and application of the Batasan’s internal rules of procedure are within its exclusive domain. Judicial courts cannot annul a legislative act merely for an alleged violation of the body’s own procedural rules, as these rules are not substantive law but are subject to modification or waiver by the body itself. Furthermore, the acts sought to be restrained were already consummated (fait accompli), making the issuance of prohibitive or mandatory writs improper. The petition, therefore, presented a non-justiciable political question.