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FACTS: Within a period of 1 year, 2 impeachment proceedings were filed against

Supreme Court Chief Justice Hilario Davide. The justiciable controversy in this case was
the constitutionality of the subsequent filing of a second complaint to controvert the
rules of impeachment provided for by law.
ISSUE: Whether or not the filing of the second impeachment complaint against Chief
Justice Hilario G. Davide, Jr. with the House of Representatives is constitutional, and
whether the resolution thereof is a political question h; as resulted in a political crisis.
HELD: Sections 16 and 17 of Rule V of the Rules of Procedure in Impeachment
Proceedings which were approved by the House of Representativesare unconstitutional.
Consequently, the second impeachment complaint against Chief Justice Hilario G.
Davide, is barred under paragraph 5, section 3 of Article XI of the Constitution.
REASONING: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.
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. 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. 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 bythe Constitution.
The framers of the Constitution also understood initiation in its ordinary meaning. Thus
when a proposal reached the floor proposing that A vote of at least one-third of all the
Members of the House shall be necessary to initiate impeachment proceedings, this
was met by a proposal to delete the line on the ground that the vote of the House does
not initiate impeachment proceeding but rather the filing of a complaint does.
Having concluded that the initiation takes place by the act of filing and referral or
endorsement of the impeachment complaint to the House Committee on Justice or, by
the filing by at least one-third of the members of the House of Representatives with the
Secretary General of the House, the meaning of Section 3 (5) of Article XI becomes clear.
Once an impeachment complaint has been initiated, another impeachment complaint
may not be filed against the same official within a one year period.
The Court in the present petitions subjected to judicial scrutiny and resolved on the
merits only the main issue of whether the impeachment proceedings initiated against
the Chief Justice transgressed the constitutionally imposed one-year time bar rule.
Beyond this, it did not go about assuming jurisdiction where it had none, nor

indiscriminately turnjusticiable issues out of decidedly political questions. Because it is


not at all the business of this Court to assert judicial dominance over the other two great
branches of the government.
PEOPLE v. POMAR
November 3, 1924, G.R. No. L-22008, Johnson, J.
(Labor Standards: Police Power, basis of social legislation)
FACTS:
Julio Pomar is the manager and person in charge of La Flor de la Isabela, a tobacco
factory pertaining to La Campania General de Tabacos de Filipinas, a corporation
duly authorized to transact business in the City of Manila. under his employ is
Macaria Fajardo, whom he granted vacation leave by reason of her pregnancy.
However, Pomar did not pay her the wages she is entitled to corresponding to 30
days before and 30 days after her delivery and confinement. Despite demands
made by her, Pomar still refused to pay Fajardo.

The CFI found Pomar guilty of violating section 13 in connection with section 15 of
Act No. 3071. POmar appealed questioning the constitutionality of the Act.

Said section 13 was enacted by the Legislature of the Philippine Islands in the
exercise of its supposed police power, with the praiseworthy purpose of
safeguarding the health of pregnant women laborers in factory, shop or place of
labor of any description, and of insuring to them, to a certain extent, reasonable
support for one month before and one month after their delivery.
ISSUE:
Whether or not Act 3071 has been adopted in the reasonable and lawful exercise of
the police power of the state.
RULING:
The police power of the state is a growing and expanding power. As civilization
develops and public conscience becomes awakened, the police power may be
extended, as has been demonstrated in the growth of public sentiment with
reference to the manufacture and sale of intoxicating liquors. But that power cannot
grow faster than the fundamental law of the state, nor transcend or violate the
express inhibition of the peoples law the constitution. If the people desire to have
the police power extended and applied to conditions and things prohibited by the
organic law, they must first amend that law.

It will also be noted from an examination of said section 13, that it takes no account
of contracts for the employment of women by the day nor by the piece. The law is
equally applicable to each case. It will hardly be contended that the person, firm or
corporation owning or managing a factory, shop or place of labor, who employs
women by the day or by the piece, could be compelled under the law to pay for
sixty days during which no services were rendered.

For all of the foregoing reasons, we are fully persuaded, under the facts and the law,
that the provisions of section 13, of Act No. 3071 of the Philippine Legislature, are
unconstitutional and void.
Therefore, the sentence of the lower court is hereby revoked, the complaint is
hereby dismissed.

Lambino Vs. Comelec


G.R. No. 174153
Oct. 25 2006
Facts: Petitioners (Lambino group) commenced gathering
signatures for an initiative petition to change the 1987
constitution, they filed a petition with the COMELEC to hold a
plebiscite that will ratify their initiative petition under RA 6735.
Lambino group alleged that the petition had the support of 6M
individuals fulfilling what was provided by art 17 of the
constitution. Their petition changes the 1987 constitution by
modifying sections 1-7 of Art 6 and sections 1-4 of Art 7 and by
adding Art 18. the proposed changes will shift the present
bicameral- presidential form of government to unicameralparliamentary. COMELEC denied the petition due to lack of
enabling law governing initiative petitions and invoked the
Santiago Vs. Comelec ruling that RA 6735 is inadequate to
implement the initiative petitions.
Issue:
Whether or Not the Lambino Groups initiative petition complies
with Section 2, Article XVII of the Constitution on amendments
to the Constitution through a peoples initiative.
Whether or Not this Court should revisit its ruling in Santiago
declaring RA 6735 incomplete, inadequate or wanting in

essential terms and conditions to implement the initiative


clause on proposals to amend the Constitution.
Whether or Not the COMELEC committed grave abuse of
discretion in denying due course to the Lambino Groups
petition.
Held: According to the SC the Lambino group failed to comply
with the basic requirements for conducting a peoples initiative.
The Court held that the COMELEC did not grave abuse of
discretion on dismissing the Lambino petition.
1. The Initiative Petition Does Not Comply with Section 2, Article
XVII of the Constitution on Direct Proposal by the People
The petitioners failed to show the court that the initiative signer
must be informed at the time of the signing of the nature and
effect, failure to do so is deceptive and misleading which
renders the initiative void.
2. The Initiative Violates Section 2, Article XVII of the
Constitution Disallowing Revision through Initiatives
The framers of the constitution intended a clear distinction
between amendment and revision, it is intended that the third
mode of stated in sec 2 art 17 of the constitution may propose
only amendments to the constitution. Merging of the legislative
and the executive is a radical change, therefore a constitutes a
revision.
3. A Revisit of Santiago v. COMELEC is Not Necessary
Even assuming that RA 6735 is valid, it will not change the
result because the present petition violated Sec 2 Art 17 to be a

valid initiative, must first comply with the constitution before


complying with RA 6735
Petition is dismissed.

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