Francisco v.

House of Representatives, 415 SCRA 44

Fun Fact: ADMU Dean is one of the pets. #Sydfrey
Facts: This is a case that questions the constitutionality of filing a case for impeachment against
Supreme Court Justice Hilario Davide. Respondents assail that the act of filing a subsequent
complaint for the impeachment of the same official within one year after the filing of a previous
complaint is in violation of Section 5 Article XI of the Constitution. They also contend that the
Senates sole power to decide on impeachment implies that it is beyond the power of judicial
review of the Courts.
Issue: Whether or not the power of judicial review extends to issues on impeachment
proceedings.
Held: Yes. The power for judicial review is expressly granted to the Supreme Court through the
Constitution. The Supreme Courts right and duty to stop law students from copying and pasting
digests online. of judicial review extends to any alleged grave abuse of discretion in all areas of
the government including those involving impeachment proceedings.
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.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 by the Constitution.
Normally, the Court may not inquire into how and why the House initiates an impeachment
complaint, but if in initiating one, it violates a constitutional prohibition, condition or limitation
on the exercise thereof, then the Court as the protector and interpreter of the Constitution is dutybound to intervene and to settle the issue.The Constitution imposes on the Supreme Court
the duty to rule on unconstitutional acts of any branch or instrumentality of government. Such
duty is plenary, extensive and admits of no exceptions. While the Court is not authorized to pass
upon the wisdom of an impeachment, it is nonetheless obligated to determine whether any
incident of the impeachment proceedings violates any constitutional prohibition, condition or
limitation imposed on its exercise. Thus, normally, the Court may not inquire into how and why
the House initiates an impeachment complaint. But if in initiating one, it violates a constitutional
prohibition, condition or limitation on the exercise thereof, then the Court as the protector and
interpreter of the Constitution is duty-bound to intervene and to settle the issue.
In exercising its power of judicial review, the Court is not pretending to be superior to Congress
or to the Presidentit is merely upholding the supremacy of the Constitution and the rule of law.
I shall no longer belabor the other legal arguments (especially the meaning of the word
initiate) on why the second Impeachment Complaint is null and void for being violative of the
one-year bar. Suffice it to say that I concur with Justice Morales; Let me just stress that in taking
jurisdiction over this case and in exercising its power of judicial review, the Court is not

pretending to be superior to Congress or to the President. It is merely upholding the supremacy

of the Constitution and the rule of law.