Marcos vs Manglapus

Posted by kaye lee on 1:16 PM

G.R. No. 88211 September 15 1989
FACTS:
Former President Marcos, after his and his family spent three year exile in Hawaii, USA, sought
to return to the Philippines. The call is about to request of Marcos family to order the
respondents to issue travel order to them and to enjoin the petition of the President's decision to
bar their return to the Philippines.
ISSUE:
Whether or not, in the exercise of the powers granted by the Constitution,
the President may prohibit the Marcoses from returning to the Philippines.
RULING:
Yes
According to Section 1, Article VII of the 1987 Constitution: "The executive
power shall be vested in the President of the Philippines." The phrase,
however, does not define what is meant by executive power although the
same article tackles on exercises of certain powers by the President such as
appointing power during recess of the Congress (S.16), control of all the
executive departments, bureaus, and offices (Section 17), power to grant
reprieves, commutations, and pardons, and remit fines and forfeitures, after conviction by final
judgment (Section 19), treaty making power (Section 21), borrowing power
(Section 20), budgetary power (Section 22), informing power (Section 23).
The Constitution may have grant powers to the President, it cannot be said
to be limited only to the specific powers enumerated in the Constitution.
Whatever power inherent in the government that is neither legislative nor
judicial has to be executive.

Estrada vs Desierto; Arroyo

Posted by kaye lee on 2:48 AM
Estrada vs Desierto G.R. No. 146710-15; Estrada vs Arroyo G.R. No. 146738, March 2 2001
[Immunity from Suit; Resignation of the President; Justiciable controversy]
FACTS:
It began in October 2000 when allegations of wrong doings involving bribe-taking, illegal
gambling, and other forms of corruption were made against Estrada before the Senate Blue
Ribbon Committee. On November 13, 2000, Estrada was impeached by the Hor and, on

December 7, impeachment proceedings were begun in the Senate during which more serious
allegations of graft and corruption against Estrada were made and were only stopped on January
16, 2001 when 11 senators, sympathetic to the President, succeeded in suppressing damaging
evidence against Estrada. As a result, the impeachment trial was thrown into an uproar as the
entire prosecution panel walked out and Senate President Pimentel resigned after casting his vote
against Estrada.
On January 19, PNP and the AFP also withdrew their support for Estrada and joined the crowd at
EDSA Shrine. Estrada called for a snap presidential election to be held concurrently with
congressional and local elections on May 14, 2001. He added that he will not run in this election.
On January 20, SC declared that the seat of presidency was vacant, saying that Estrada
constructively resigned his post. At noon, Arroyo took her oath of office in the presence of the
crowd at EDSA as the 14th President. Estrada and his family later left Malacaang Palace. Erap,
after his fall, filed petition for prohibition with prayer for WPI. It sought to enjoin the respondent
Ombudsman from conducting any further proceedings in cases filed against him not until his
term as president ends. He also prayed for judgment confirming Estrada to be the lawful and
incumbent President of the Republic of the Philippines temporarily unable to discharge the duties
of his office.
ISSUE(S):
1. WoN the petition presents a justiciable controversy.
2. WoN Estrada resigned as President.
3. WoN Arroyo is only an acting President.
4. WoN the President enjoys immunity from suit.
5. WoN the prosecution of Estrada should be enjoined due to prejudicial publicity.
RULING:
1. Political questions- "to those questions which, under the Constitution, are to be decided by the
people in their sovereign capacity, or in regard to which full discretionary authority has been
delegated to the legislative or executive branch of the government. It is concerned with issues
dependent upon the wisdom, not legality of a particular measure."
Legal distinction between EDSA People Power I EDSA People Power II:
EDSA I
EDSA II
exercise of the people power of revolution
exercise of people power of freedom of
which overthrew the whole government.
speech and freedom of assembly to petition
the government for redress of grievances
which only affected the office of the President.
extra constitutional and the legitimacy of the intra constitutional and the resignation of the
new government that resulted from it cannot be sitting President that it caused and the
the subject of judicial review
succession of the Vice President as President
are subject to judicial review.
presented a political question;
involves legal questions.
The cases at bar pose legal and not political questions. The principal issues for resolution require
the proper interpretation of certain provisions in the 1987 Constitution: Sec 1 of Art II, and Sec 8
of Art VII, and the allocation of governmental powers under Sec 11 of Art VII. The issues

likewise call for a ruling on the scope of presidential immunity from suit. They also involve the
correct calibration of the right of petitioner against prejudicial publicity.
2. Elements of valid resignation: (a)an intent to resign and (b) acts of relinquishment. Both were
present when President Estrada left the Palace.
Totality of prior contemporaneous posterior facts and circumstantial evidence bearing material
relevant issuesPresident Estrada is deemed to have resigned constructive resignation.
SC declared that the resignation of President Estrada could not be doubted as confirmed by his
leaving Malacaan Palace. In the press release containing his final statement:
1. He acknowledged the oath-taking of the respondent as President;
2. He emphasized he was leaving the Palace for the sake of peace and in order to begin the
healing process (he did not say that he was leaving due to any kind of disability and that he was
going to reassume the Presidency as soon as the disability disappears);
3. He expressed his gratitude to the people for the opportunity to serve them as President
(without doubt referring to the past opportunity);
4. He assured that he will not shirk from any future challenge that may come in the same service
of the country;
5. He called on his supporters to join him in promotion of a constructive national spirit of
reconciliation and solidarity.
Intent to resignmust be accompanied by act of relinquishmentact or omission before, during
and after January 20, 2001.
3. The Congress passed House Resolution No. 176 expressly stating its support to Gloria
Macapagal-Arroyo as President of the Republic of the Philippines and subsequently passed H.R.
178 confirms the nomination of Teofisto T. Guingona Jr. As Vice President. Senate passed HR
No. 83 declaring the Impeachment Courts as Functius Officio and has been terminated. It is clear
is that both houses of Congress recognized Arroyo as the President. Implicitly clear in that
recognition is the premise that the inability of Estrada is no longer temporary as the Congress has
clearly rejected his claim of inability.
The Court therefore cannot exercise its judicial power for this is political in nature and addressed
solely to Congress by constitutional fiat. In fine, even if Estrada can prove that he did not resign,
still, he cannot successfully claim that he is a President on leave on the ground that he is merely
unable to govern temporarily. That claim has been laid to rest by Congress and the decision that
Arroyo is the de jure, president made by a co-equal branch of government cannot be reviewed by
this Court.
4. The cases filed against Estrada are criminal in character. They involve plunder, bribery and
graft and corruption. By no stretch of the imagination can these crimes, especially plunder which
carries the death penalty, be covered by the alleged mantle of immunity of a non-sitting
president. He cannot cite any decision of this Court licensing the President to commit criminal
acts and wrapping him with post-tenure immunity from liability. The rule is that unlawful acts of
public officials are not acts of the State and the officer who acts illegally is not acting as such but
stands in the same footing as any trespasser.
5. No. Case law will tell us that a right to a fair trial and the free press are incompatible. Also,
since our justice system does not use the jury system, the judge, who is a learned and legally

enlightened individual, cannot be easily manipulated by mere publicity. The Court also said that
Estrada did not present enough evidence to show that the publicity given the trial has influenced
the judge so as to render the judge unable to perform. Finally, the Court said that the cases
against Estrada were still undergoing preliminary investigation, so the publicity of the case
would really have no permanent effect on the judge and that the prosecutor should be more
concerned with justice and less with prosecution.
Soliven v Makasiar Nov 14, 1988 G.R. No. 82585
Per Curiam
(Topic on Warrant Issued by RTC)
Facts:
Soliven broadcasted the statement that President Aquino hid under her bed during a
coup d' etat. The President sued for libel. Soliven claimed that he can't be sued
because the President was immune from suit.
Issue: WON Beltran's rights were violated when the RTC issued a warrant of arrest
without personally examining the complainant and the witnesses to determine
probable cause.
Held: No
Ratio:
In satisfying himself of the existence of probable cause to issue a warrant of arrest,
the judge isn't required to examine the complainant and the witnesses.
He shall only personally evaluate the report and supporting documents submitted
by the fiscal regarding the existence of probable cause and issue a warrant of arrest
on the basis thereof.
Also, if he finds no probable cause, he may disregard the fiscal's report and required
the submission of supporting affidavits of witnesses to aid him in arriving at a
conclusion as to the existence of probable cause.
Otherwise, judges would be burdened with preliminary investigation instead of
hearing cases.

Neri vs Senate Committee on Accountability of Public

Officers

Posted by kaye lee on 8:54 PM

G.R.No. 180643, March 25 2008 [Executive Privilege]
FACTS:
The Senate issued various Senate Resolutions directing SBRC, among others, to conduct an
investigation regarding the NBN-ZTE deal. Neri, the head of NEDA, was then invited to testify
before the Senate Blue Ribbon. He disclosed that the COMELEC Chairman Abalos offered him
P200M in exchange for his approval of the NBN Project, that he informed PGMA about the
bribery and that she instructed him not to accept the bribe. However, when probed further on
what they discussed about the NBN Project, he refused to answer, invoking executive
privilege. In particular, he refused to answer the questions on (a) whether or not President
Arroyo followed up the NBN Project, (b) whether or not she directed him to prioritize it,
and (c) whether or not she directed him to approve. As a result, the Senate cited him for
contempt.
ISSUE:
Whether or not the communications elicited by the 3 questions covered by executive privilege.
RULING:
The SC recognized the executive privilege which is the Presidential communications privilege.
It pertains to communications, documents or other materials that reflect presidential decisionmaking and deliberations and that the President believes should remain confidential.
Presidential communications privilege applies to decision-making of the President. It is rooted in
the constitutional principle of separation of power and the Presidents unique constitutional role.
The claim of executive privilege is highly recognized in cases where the subject of inquiry
relates to a power textually committed by the Constitution to the President, such as the area of
military and foreign relations. The information relating to these powers may enjoy greater
confidentiality than others.
Elements of presidential communications privilege:
1)
The protected communication must relate to a quintessential and non-delegable
presidential power. - i.e. the power to enter into an executive agreement with other countries.
This authority of the President to enter into executive agreements without the concurrence of the
Legislature has traditionally been recognized in Philippine jurisprudence.
2)
The communication must be authored or solicited and received by a close advisor of
the President or the President himself. The judicial test is that an advisor must be in
operational proximity with the President.
3)
The presidential communications privilege remains a qualified privilege that may be
overcome by a showing of adequate need, such that the information sought likely contains
important evid
ence and by the unavailability of the information elsewhere by an appropriate investigating
authority. - there is no adequate showing of a compelling need that would justify the limitation of
the privilege and of the unavailability of the information elsewhere by an appropriate
investigating authority.

Fernando Lopez vs Gerardo Roxas

October 30, 2011
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17 SCRA 756 Political Law Constitutional Law Judicial Power Defined

Fernando Lopez and Gerardo Roxas were the candidates for Vice President in the 1965 elections.
Lopez won the election. Roxas appealed his loss before the Presidential Electoral Tribunal
(PET). The PET was created by RA 1793. It is provided in the law that:
There shall be an independent Presidential Electoral Tribunal . . . which shall be the sole judge
of all contests relating to the election, returns, and qualifications of the president-elect and the
Vice-president elect of the Philippines.
In effect, a losing candidate would have the right to appeal his loss. Lopez assailed the law and
he sought to enjoin Roxas and the PET from proceeding with the case. Lopez averred that the
PET is unconstitutional for it was not provided for in the constitution. Also, since the PET is
composed of the Chief Justice and the other ten members of the SC any decision of the PET
cannot be validly appealed before the SC or that there may be conflict that may arise once a PET
decision is appealed before the SC.
ISSUE: Whether or not the PET is a valid body.
HELD: Yes. In coming up with the PET, the Congress merely conferred a new function to the
Supreme Court. Such is within its power, the Constitution allowed Congress to determine which
body should decide controversies relating to the election of the President or the Vice President.

RA 1793 did not create another court within the SC for pursuant to the Constitution, the Judicial
power shall be vested in one SC and in such inferior courts as may be established by law
The Supreme Court went on to emphasize that the fundamental law vests in the judicial branch
of the government, not merely some specified or limited judicial power, but the judicial power
under our political system, and, accordingly, the entirety or all of said power, except, only, so
much as the Constitution confers upon some other agency, such as the power to judge all
contests relating to the election, returns and qualifications of members of the Senate and those
of the House of Representatives, which is vested by the fundamental law solely in the Senate
Electoral Tribunal and the House Electoral Tribunal, respectively.
Judicial power is the authority to settle justiciable controversies or disputes involving rights that
are enforceable and demandable before the courts of justice or the redress of wrongs for
violations of such rights. The proper exercise of said authority requires legislative action: (1)
defining such enforceable and demandable rights and/or prescribing remedies for violations
thereof; and (2) determining the court with jurisdiction to hear and decide said controversies or
disputes, in the first instance and/or on appeal. For this reason, the Constitution ordains that
Congress shall have the power to define, prescribe, and apportion the jurisdiction of the various
courts, subject to the limitations set forth in the fundamental law.
The SC ruled that the PET is not in conflict with the constitution. RA 1793 merely added the
courts jurisdiction and such can be validly legislated by Congress. It merely conferred upon the
SC additional functions i.e., the functions of the PET. This is valid because the determining of
election contests is essentially judicial.

Civil Liberties Union vs Executive Secretary

October 31, 2011
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194 SCRA 317 Political Law Ex Officio Officials Members of the Cabinet Singularity of
Office EO 284
In July 1987, then President Corazon Aquino issued Executive Order No. 284 which allowed
members of the Cabinet, their undersecretaries and assistant secretaries to hold other government
offices or positions in addition to their primary positions subject to limitations set therein. The
Civil Liberties Union (CLU) assailed this EO averring that such law is unconstitutional. The
constitutionality of EO 284 is being challenged by CLU on the principal submission that it adds
exceptions to Sec 13, Article 7 of the Constitution which provides:
Sec. 13. The President, Vice-President, the Members of the Cabinet, and their deputies or
assistants shall not, unless otherwise provided in this Constitution, hold any other office or
employment during their tenure. They shall not, during said tenure, directly or indirectly practice
any other profession, participate in any business, or be financially interested in any contract with,
or in any franchise, or special privilege granted by the Government or any subdivision, agency,
or instrumentality thereof, including government-owned or controlled corporations or their
subsidiaries. They shall strictly avoid conflict of interest in the conduct of their office.
CLU avers that by virtue of the phrase unless otherwise provided in this Constitution, the only
exceptions against holding any other office or employment in Government are those provided in
the Constitution, namely: (i) The Vice-President may be appointed as a Member of the Cabinet
under Sec 3, par. (2), Article 7; and (ii) the Secretary of Justice is an ex-officio member of the
Judicial and Bar Council by virtue of Sec 8 (1), Article 8.
ISSUE: Whether or not EO 284 is constitutional.
HELD: No, it is unconstitutional. It is clear that the 1987 Constitution seeks to prohibit the
President, Vice-President, members of the Cabinet, their deputies or assistants from holding
during their tenure multiple offices or employment in the government, except in those cases
specified in the Constitution itself and as above clarified with respect to posts held without
additional compensation in an ex-officio capacity as provided by law and as required by the
primary functions of their office, the citation of Cabinet members (then called Ministers) as
examples during the debate and deliberation on the general rule laid down for all appointive
officials should be considered as mere personal opinions which cannot override the constitutions
manifest intent and the peoples understanding thereof.
In the light of the construction given to Sec 13, Art 7 in relation to Sec 7, par. (2), Art IX-B of the
1987 Constitution, EO 284 is unconstitutional. Ostensibly restricting the number of positions that

Cabinet members, undersecretaries or assistant secretaries may hold in addition to their primary
position to not more than 2 positions in the government and government corporations, EO 284
actually allows them to hold multiple offices or employment in direct contravention of the
express mandate of Sec 13, Art 7 of the 1987 Constitution prohibiting them from doing so, unless
otherwise provided in the 1987 Constitution itself.

Cecilio Rafael vs Embroidery and Apparel Control &

Inspection Board
October 31, 2011
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21 SCRA 336 Political Law Appointments When Not Bypassed by a Law

In 1961, Republic Act No. 3137 was passed. This law created the Embroidery and Apparel
Control and Inspection Board (EACIB). Section 2 thereof also provided that the Board shall be
composed of:
(1) a representative from the Bureau of Customs to act as Chairman, to be designated by the
Secretary of Finance;
(2) a representative from the Central Bank to be designated by its Governor;
(3) a representative from the Department of Commerce and Industry to be designated by the
Secretary of Commerce and Industry;

(4) a representative from the National Economic Council to be designated by its Chairman; and
(5) a representative from the private sector coming from the Association of Embroidery and
Apparel Exporters of the Philippines.
Later, in the performance of its duties, the EACIB made certain assessments against Cecilio
Rafael but the latter refused to comply. Rafael sued EACIB and he averred that RA 3137 is
unconstitutional for while Congress may create an office it cannot specify who shall be
appointed therein; that the members of the EACIB can only be appointed by the President in
accordance with Article 7, Sec. 10 2 of the Constitution; that since the Act prescribes that the
chairman and members of the EACIB should come from specified offices, it is equivalent to a
declaration by Congress as to who should be appointed, thereby infringing the constitutional
power of the President to make appointments.
ISSUE: Whether or not RA 3137 bypassed the appointing power of the president.
HELD: No. The Supreme Court noted that indeed the appointing power is the exclusive
prerogative of the President, upon which no limitations maybe imposed by Congress, except
those resulting from the need of securing the concurrence of the Commission on Appointments
and from the exercise of the limited power to prescribe the qualifications to the given appointive
office.
In the case at bar, the representatives in the EACIB are not appointed by the Department Heads.
They are merely going to be designated hence whoever was designated was merely sitting as an
ex officio member. It must also be noted that Congress took care to specify that the
representatives should come from the Bureau of Customs, Central Bank, Department of
Commerce and Industry and the National Economic Council. The obvious reason must be
because these departments and/or bureaus perform functions which have a direct relation to the
importation of raw materials, the manufacture thereof into embroidery and apparel products and
their subsequent exportation abroad. There is no attempt in RA 3137 to deprive the President of
his power to make appointments. The law is not unconstitutional.

Government of the Philippine Islands vs Milton Springer

January 5, 2013
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50 Phil 259 Law on Public Officers Power to Appoint is Essentially Executive

Sometime in the 1900s, the National Coal Company (NCC) was created by the Philippine
Congress. The law created it (Act No. 2822) provides that: The voting power shall be vested
exclusively in a committee consisting of the Governor-General, the President of the Senate, and
the Speaker of the House of Representatives.
In November 1926, the Governor-General (Leonard Wood) issued E.O. No. 37 which divested
the voting rights of the Senate President and House Speaker in the NCC. The EO emphasized
that the voting right should be solely lodged in the Governor-General who is the head of the
government (President at that time was considered the head of state but does not manage
government affairs). A copy of the said EO was furnished to the Senate President and the House
Speaker.
However, in December 1926, NCC held its elections and the Senate President as well as the
House Speaker, notwithstanding EO No. 37 and the objection of the Governor-General, still
elected Milton Springer and four others as Board of Directors of NCC. Thereafter, a quo
warranto proceeding in behalf of the government was filed against Springer et al questioning the
validity of their election into the Board of NCC.
ISSUE: Whether or not the Senate President as well as the House Speaker can validly elect the
Board Members of NCC.
HELD: No. E.O. No 37 is valid. It is in accordance with the doctrine of separation of powers.
The Supreme Court emphasized that the legislature creates the public office but it has nothing to
do with designating the persons to fill the office. Appointing persons to a public office is
essentially executive. The NCC is a government owned and controlled corporation. It was
created by Congress. To extend the power of Congress into allowing it, through the Senate
President and the House Speaker, to appoint members of the NCC is already an invasion of
executive powers. The Supreme Court however notes that indeed there are exceptions to this rule
where the legislature may appoint persons to fill public office. Such exception can be found in

the appointment by the legislature of persons to fill offices within the legislative branch this
exception is allowable because it does not weaken the executive branch.

Quintos-Deles v. COA

9/22/2014
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Constitutional Law. Political Law.

Quintos-Deles v. COA
177 SCRA 259
FACTS:
On April 6, 1988, petitioner and three others were appointed Sectoral
Representatives by the President pursuant to Article VII, Section 16, paragraph 2
and Article XVIII, Section 7 of the Constitution. In the May 12, 1988 meeting of the
Committee on Appointments ruled against the position of petitioner Deles.
Petitioner Teresita Quintos-Deles contends that her appointment as Sectoral
Representative for Women by the President does not require confirmation by the
Commission on Appointments to qualify her to take her seat in the House of
Representatives.
ISSUE:
Whether or not the Constitution requires the appointment of sectoral
representatives to the House of Representatives to be confirmed by the Commission
on Appointments
HELD:
The first group of people that may be appointed by the president, as previously
stated in the Sarmiento v. Mison case, are the heads of the executive departments,
ambassadors, other public ministers and consuls, or officers of the armed forces
from the rank of colonel or naval captain, and other officers whose appointments
are vested in him in this Constitution. Since the seats reserved for sectoral
representatives in paragraph 2, Section 5, Art. VI may be filled by appointment by
the President by express provision of Section 7, Art. XVIII of the Constitution, it is
indubitable that sectoral representatives to the House of Representatives are
among the other officers whose appointments are vested in the President in this
Constitution, referred to in the first sentence of Section 16, Article VII (or the first

group of people who may be appointed) whose appointments are subject to

confirmation by the Commission on Appointments.

CARLOS CUNANAN vs. JORGE TAN, JR.

Facts:
Petitioner sought to nullify the ad interim appointment of Jorge Tan Jr as acting
Deputy Administrator of the Reforestation Administration. Cunanan was formerly
appointed in the same position but was later on rejected by the Commision of
Appointment prompting the President to replace him with Jorge Tan Jr immediately
without his consent.
Filing the quo warranto proceeding to the Supreme Court, Cunanan questions the
validity of the convened Commission of Appointments citing irregularities as to the
numbers of members comprising the same.
Issue:
WON the appointment of Jorge Tan Jr is valid.
Ruling:

With the reorganization of the Commission of Appointment, it was ruled that such is
a power vested in the Congress as they deem it proper taking into consideration the
proportionate numbers of the members of the Commission of Appointment
members as to their political affiliations. However, with their reorganization, this
affected a third party's right which they rejected as its result. To correct this, the
Supreme Court declared the reinstatement of the petitioner and ordered respondent
to vacate and turn over the office in contention.

LLAMAS v. EXEC. SEC. ORBOS, OCAMPO III

October 26, 2012 Leave a comment

October 15, 1991 (G.R. No. 99031)
PARTIES:
Petitioner: RODOLFO D. LLAMAS
Respondent: EXECUTIVE SECRETARY OSCAR ORBOS and MARIANO UN OCAMPO III

FACTS:
Ocampo III was the governor of Tarlac Province. Llamas together with some other complainants
filed an administrative case against Ocampo III for alleged acts constituting graft and corruption.
Ocampo III was found guilty. He was suspended for office for 90 days hence his vice governor,
Llamas, assumed office. In not less than 30 days however, Ocampo III returned with an AO
showing that he was pardoned hence he can resume office without completing the 90 day
suspension imposed upon him.
The petitioner argues that President may grant executive clemency only in criminal cases. They
say that the qualifying phrase after conviction by final judgment applies solely to criminal
cases, and no other law allows the grant of executive clemency or pardon to anyone who has
been convicted in an administrative case, allegedly because the word conviction refers only to
criminal cases.
ISSUE: WON the President of the Philippines has the power to grant executive clemency in
administrative cases.
HELD:
Yes. It is not specified in the constitution whether it may be considered under criminal or
administrative cases. , if the law does not distinguish, so we must not distinguish. The
Constitution does not distinguish between which cases executive clemency may be exercised by
the President, with the sole exclusion of impeachment cases. By the same token, if executive
clemency may be exercised only in criminal cases, it would indeed be unnecessary to provide for
the exclusion of impeachment cases from the coverage of Article VII, Section 19 of the
Constitution. Cases of impeachment are automatically excluded inasmuch as the same do not
necessarily involve criminal offenses.
The do not clearly see any valid and convincing reason why the President cannot grant executive
clemency in administrative cases. It is the courts considered view that if the President can grant
reprieves, commutations and pardons, and remit fines and forfeitures in criminal cases, with
much more reason can she grant executive clemency in administrative cases, which are clearly
less serious than criminal offenses.
The court stressed, however, that when we say the President can grant executive clemency in
administrative cases, we refer only to all administrative cases in the Executive branch, not in the
Judicial or Legislative branches of the government.
In criminal cases, the quantum of evidence required to convict an individual is proof beyond
reasonable doubt. On the other hand, in administrative cases, the quantum of evidence required is
mere substantial evidence to support a decision.