GR L 76180; (October, 1986) (Digest)
G.R. No. L-76180 October 24, 1986
IN RE: SATURNINO V. BERMUDEZ, petitioner.
FACTS
Petitioner Saturnino V. Bermudez, a lawyer, filed a petition for declaratory relief directly with the Supreme Court. He sought an interpretation of Section 5, Article XVIII of the then-proposed 1986 Constitution. This transitory provision stated: “The six-year term of the incumbent President and Vice-President elected in the February 7, 1986 election is, for purposes of synchronization of elections, hereby extended to noon of June 30, 1992.” Petitioner claimed this provision was unclear and asked the Court to declare definitively whether it referred to President Corazon C. Aquino and Vice-President Salvador Laurel, or to Ferdinand E. Marcos and Arturo Tolentino, who were the candidates in the disputed February 7, 1986, snap election. The petition impleaded no respondents.
ISSUE
The primary issue was whether the Supreme Court could take cognizance of the petition for declaratory relief regarding the interpretation of a constitutional provision concerning the identity of the incumbent President and Vice-President.
RULING
The Supreme Court dismissed the petition outright for lack of jurisdiction and lack of cause of action. On jurisdiction, the Court held it assumes no original jurisdiction over petitions for declaratory relief, which properly fall within the jurisdiction of lower courts. Furthermore, the petition effectively constituted a suit against the incumbent President, who enjoys immunity from suit during her tenure.
On the merits, the Court found the petition stated no cause of action. It ruled the alleged ambiguity in the constitutional provision was “manifestly gratuitous.” The Court took judicial notice that it was a matter of public record and common knowledge the Constitutional Commission referred to President Aquino and Vice-President Laurel. This conclusion was bolstered by the provision’s second paragraph, which scheduled the next regular elections for 1992, logically synchronizing with the extended term of the incumbents recognized by the Commission. The Court cited its prior resolutions in related cases (e.g., Lawyers League for a Better Philippines vs. Aquino), which held the legitimacy of the Aquino government was a political question settled by the people’s acceptance and effective control, making it a de jure government. Thus, there was no justiciable ambiguity to resolve. The separate concurring opinions reinforced the dismissal, noting the proposed constitution was not yet ratified at the time of filing and that the determination of election winners is a function constitutionally vested in the legislative department, not the judiciary.