1/23/24, 11:41 PM Francisco vs. House of Representatives Case Digest - G.R. No. 160261 - Nov.

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ERNESTO B. FRANCISCO, JR., petitioner,
NAGMAMALASAKIT NA MGA MANANANGGOL NG MGA MANGGAGAWANG PILIPINO, INC., ITS Get it fresh
OFFICERS AND MEMBERS, petitioner-in-intervention,
WORLD WAR II VETERANS LEGIONARIES OF THE PHILIPPINES, INC., petitioner-in-intervention,
vs.
THE HOUSE OF REPRESENTATIVES, REPRESENTED BY SPEAKER JOSE G. DE VENECIA, THE SENATE, Your email address
REPRESENTED BY SENATE PRESIDENT FRANKLIN M. DRILON, REPRESENTATIVE GILBERTO C.
TEODORO, JR. AND REPRESENTATIVE FELIX WILLIAM B. FUENTEBELLA, respondents.
JAIME N. SORIANO, respondent-in-Intervention,
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SENATOR AQUILINO Q. PIMENTEL, respondent-in-intervention.

GR NO. 160261
Nov. 10, 2003

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On July 22, 2002, the House of Representatives adopted a Resolution, which directed the Committee
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on Justice “to conduct an investigation, in aid of legislation, on the manner of disbursements and
expenditures by the Chief Justice of the Supreme Court of the Judiciary Development Fund (JDF). On
June 2, 2003, former President Joseph E. Estrada filed an impeachment complaint (first impeachment
complaint) against Chief Justice Hilario G. Davide Jr. and seven Associate Justices of this Court for Categories
“culpable violation of the Constitution, betrayal of the public trust and other high crimes.” The
complaint was endorsed by Representatives Suplico, Zamora and Dilangalen, and was referred to Select Category
the House Committee on Justice in accordance with Section 3(2) of Article XI of the Constitution.

The House Committee on Justice ruled that the first impeachment complaint was “sufficient in form,” Recent Posts

but voted to dismiss the same for being insufficient in substance.

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1/23/24, 11:41 PM Francisco vs. House of Representatives Case Digest - G.R. No. 160261 - Nov. 10, 2003 - Legal Assassins

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On October 23, 2003, the second impeachment complaint was filed with the Secretary General of Bryan Aldrich on Civil Law Audio
Lectures
the House against Chief Justice Hilario G. Davide, Jr., founded on the alleged results of the legislative
inquiry initiated by above-mentioned House Resolution. This second impeachment complaint was Bryan Aldrich Albio on Civil Law
accompanied by a “Resolution of Endorsement/Impeachment” signed by at least one-third (1/3) of all Audio Lectures

the Members of the House of Representatives. legalassassins on Taxation Law

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Thus arose the instant petitions against the House of Representatives, et. al., most of which petitions
contend that the filing of the second impeachment complaint is unconstitutional as it violates the 29 30 31

provision of Section 5 of Article XI of the Constitution that “[n]o impeachment proceedings shall be
initiated against the same official more than once within a period of one year.”
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ISSUE:
WON Constitution has excluded impeachment proceedings from the coverage of judicial review.
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No. In cases of conflict, the judicial department is the only constitutional organ, which can be called Entries feed
upon to determine the proper allocation of powers between the several departments and among Comments feed
the integral or constituent units thereof.
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The Constitution is a definition of the powers of government. Who is to determine the nature, scope
and extent of such powers? The Constitution itself has provided for the instrumentality of the
judiciary as the rational way. And when the judiciary mediates to allocate constitutional boundaries,
it does not assert any superiority over the other departments; it does not in reality nullify or 
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1/23/24, 11:41 PM Francisco vs. House of Representatives Case Digest - G.R. No. 160261 - Nov. 10, 2003 - Legal Assassins
invalidate an act of the legislature, but only asserts the solemn and sacred obligation assigned to it
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by the Constitution to determine conflicting claims of authority under the Constitution and to
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establish for the parties in an actual controversy the rights which that instrument secures and
guarantees to them. This is in truth all that is involved in what is termed “judicial supremacy” which
properly is the power of judicial review under the Constitution. More than that, courts accord the
presumption of constitutionality to legislative enactments, not only because the legislature is
presumed to abide by the Constitution but also because the judiciary in the determination of actual
cases and controversies must reflect the wisdom and justice of the people as expressed through
their representatives in the executive and legislative departments of the government.

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As pointed out by Justice Laurel, this “moderating power” to “determine the proper allocation of
powers” of the different branches of government and “to direct the course of government along
constitutional channels” is inherent in all courts as a necessary consequence of the judicial power
itself, which is “the power of the court to settle actual controversies involving rights which are legally
demandable and enforceable.”

To determine the merits of the issues raised in the instant petitions, this Court must necessarily turn
to the Constitution itself which employs the well-settled principles of constitutional construction.

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First, verba legis, that is, wherever possible, the words used in the Constitution must be given their
ordinary meaning except where technical terms are employed.

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1/23/24, 11:41 PM Francisco vs. House of Representatives Case Digest - G.R. No. 160261 - Nov. 10, 2003 - Legal Assassins
We look to the language of the document itself in our search for its meaning. We do not of course
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stop there, but that is where we begin. It is to be assumed that the words in which constitutional
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provisions are couched express the objective sought to be attained. They are to be given their
ordinary meaning except where technical terms are employed in which case the significance thus
attached to them prevails. As the Constitution is not primarily a lawyer’s document, it being essential
for the rule of law to obtain that it should ever be present in the people’s consciousness, its
language as much as possible should be understood in the sense they have in common use. What it
says according to the text of the provision to be construed compels acceptance and negates the
power of the courts to alter it, based on the postulate that the framers and the people mean what
they say. Thus, these are the cases where the need for construction is reduced to a minimum.

Second, where there is ambiguity, ratio legis est anima. The words of the Constitution should be
interpreted in accordance with the intent of its framers.

A foolproof yardstick in constitutional construction is the intention underlying the provision under
consideration. Thus, it has been held that the Court in construing a Constitution should bear in mind
the object sought to be accomplished by its adoption, and the evils, if any, sought to be prevented or
remedied. A doubtful provision will be examined in the light of the history of the times, and the
condition and circumstances under which the Constitution was framed. The object is to ascertain the
reason which induced the framers of the Constitution to enact the particular provision and the
purpose sought to be accomplished thereby, in order to construe the whole as to make the words
consonant to that reason and calculated to effect that purpose.

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Finally, ut magis valeat quam pereat. The Constitution is to be interpreted as a whole.

It is a well-established rule in constitutional construction that no one provision of the Constitution is

to be separated from all the others, to be considered alone, but that all the provisions bearing upon
a particular subject are to be brought into view and to be so interpreted as to effectuate the great
purposes of the instrument. Sections bearing on a particular subject should be considered and
interpreted together as to effectuate the whole purpose of the Constitution and one section is not to
be allowed to defeat another, if by any reasonable construction, the two can be made to stand
together.

In other words, the court must harmonize them, if practicable, and must lean in favor of a
construction which will render every word operative, rather than one which may make the words
idle and nugatory.
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1/23/24, 11:41 PM Francisco vs. House of Representatives Case Digest - G.R. No. 160261 - Nov. 10, 2003 - Legal Assassins
If, however, the plain meaning of the word is not found to be clear, resort to other aids is available.
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While it is permissible in this jurisdiction to consult the debates and proceedings of the
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constitutional convention in order to arrive at the reason and purpose of the resulting Constitution,
resort thereto may be had only when other guides fail as said proceedings are powerless to vary the
terms of the Constitution when the meaning is clear.

Debates in the constitutional convention “are of value as showing the views of the individual
members, and as indicating the reasons for their votes, but they give us no light as to the views of
the large majority who did not talk, much less of the mass of our fellow citizens whose votes at the
polls gave that instrument the force of fundamental law. We think it safer to construe the
constitution from what appears upon its face.” The proper interpretation therefore depends more
on how it was understood by the people adopting it than in the framers’ understanding thereof.

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