Indeed, a member of the House of Representatives has standing to maintain inviolate the prerogatives, powers and privileges vested by the Constitution in his office.83 The framers of the Constitution also understood initiation in its ordinary meaning. As for a legislator, he is allowed to sue to question the validity of any official action which he claims infringes his prerogatives as a legislator.
This Court opts to grant standing to most of the petitioners, given their allegation that any impending transmittal to the Senate of the Articles of Impeachment and the ensuing trial of the Chief Justice will necessarily involve the expenditure of public funds. At all events, courts are vested with discretion as to whether or not a taxpayer's suit should be entertained. It is not sufficient that he has merely a general interest common to all members of the public. Before he can invoke the power of judicial review, however, he must specifically prove that he has sufficient interest in preventing the illegal expenditure of money raised by taxation and that he would sustain a direct injury as a result of the enforcement of the questioned statute or contract. In the case of a taxpayer, he is allowed to sue where there is a claim that public funds are illegally disbursed, or that public money is being deflected to any improper purpose, or that there is a wastage of public funds through the enforcement of an invalid or unconstitutional law. In fine, when the proceeding involves the assertion of a public right, the mere fact that he is a citizen satisfies the requirement of personal interest. San Beda College of Law – Alabang Constitutional Law 2 Case Digests that he is about to be subjected to some burdens or penalties by reason of the statute or act complained of. It must appear that the person complaining has been or is about to be denied some right or privilege to which he is lawfully entitled or Section 1-C, SY ’06-‘07 He must be able to show, not only that the law or any government act is invalid, but also that he sustained or is in imminent danger of sustaining some direct injury as a result of its enforcement, and not merely that he suffers thereby in some indefinite way. When suing as a citizen, the interest of the petitioner assailing the constitutionality of a statute must be direct and personal. Verily, the Constitution is to be interpreted as a whole and "one section is not to be allowed to defeat another." Both are integral components of the calibrated system of independence and interdependence that insures that no branch of government act beyond the powers assigned to it by the Constitution. There exists no constitutional basis for the contention that the exercise of judicial review over impeachment proceedings would upset the system of checks and balances. At the same time, the corollary doctrine of checks and balances which has been carefully calibrated by the Constitution to temper the official acts of each of these three branches must be given effect without destroying their indispensable co-equality. In passing over the complex issues arising from the controversy, this Court is ever mindful of the essential truth that the inviolate doctrine of separation of powers among the legislative, executive or judicial branches of government by no means prescribes for absolute autonomy in the discharge by each of that part of the governmental power assigned to it by the sovereign people.
Both its resolution and protection of the public interest lie in adherence to, not departure from, the Constitution. Held: In any event, it is with the absolute certainty that our Constitution is sufficient to address all the issues which this controversy spawns that this Court unequivocally pronounces, at the first instance, that the feared resort to extra-constitutional methods of resolving it is neither necessary nor legally permissible. with the House of Representatives falls within the one year bar provided in the Constitution and whether the resolution thereof is a political question – has resulted in a political crisis. Issue: Whether or Not the filing of the second impeachment complaint against Chief Justice Hilario G. The justiciable controversy poised in front of the Court was the constitutionality of the subsequent filing of a second complaint to controvert the rules of impeachment provided for by law. HOUSE OF REPRESENTATIVES Facts: Impeachment proceedings were filed against Supreme Court Chief Justice Hilario Davide.
San Beda College of Law – Alabang Constitutional Law 2 Case Digests THE NATURE OF THE CONSTITUTION AND ITS RELATION WITH THE COURTS FRANCISCO VS. I NTRODUCTI ON TO CONSTI TUTI ONA L LAW 2 San Beda College of Law – Alabang Constitutional Law 2 Case Digests