GROUP 6 CASES

BENIGNO S. AQUINO, JR. vs. MILITARY COMMISSION 2, et al.

Facts:

In September 1972, following Martial Law, Aquino was arrested and taken to Fort Bonifacio. He sought a
Writ of Habeas Corpus, denied by the Supreme Court (SC). Aquino contested the denial, challenged
martial law, and questioned the military court's authority to try him. He faced charges before the military
court but argued that it lacked jurisdiction, as civilian courts were still functional, and a military trial
violated due process.

Issue:

Whether Aquino was afforded due process in a military court.

Held:

Yes. Martial law requires civilians to yield to military jurisdiction for public safety. Due process is not tied
to a specific tribunal. A military tribunal with jurisdiction, formal accusation, notice, defense opportunity,
and an impartial trial meets due process. Essential fairness, not a particular judicial form, is key. The
Military Commission's procedures, per Presidential Decree No. 39, ensure due process, applying
recognized rules of evidence. Aquino's claim that military tribunals destroy constitutional rights lacks
justification.

Pormento vs. Estrada

Facts:

Petitioner, Atty. Evillo C. Pormento, questioned Joseph Ejercito Estrada's eligibility for presidential
reelection in the May 10, 2010, elections. Pormento's petition for disqualification was denied by the
COMELEC, and his subsequent motion for reconsideration was also rejected. Pormento filed a petition
for certiorari on May 7, 2010, seeking judicial review. However, he did not request a stay or injunction,
and Estrada participated in the elections, securing the second-highest number of votes but not winning.

Issue:

Whether Joseph Ejercito Estrada was covered by the constitutional ban on presidential reelection,
specifically interpreting the phrase "any reelection" in Section 4, Article VII of the Constitution.

Ruling:

Yes. As Estrada was not elected President for the second time, the issue of his "reelection" became
hypothetical and speculative. The lack of a live controversy or adverse legal interests prevented the Court
from providing specific relief, rendering the case non-justiciable. Thus, the Supreme Court dismissed the
petition, citing its mootness. Therefore, the petition was denied due course and dismissed.
Estrada vs. Arroyo

Facts:

Estrada, the petitioner, contested the respondent's (Arroyo) claim to the presidency, asserting that his
departure from Malacañang on January 20, 2001, aimed to calm tensions during EDSA demonstrations
demanding his resignation. Estrada denied resigning, expressing intent to return after resolving the
situation but alleged prevention from doing so.

Issue:

Whether Arroyo is a legitimate (de jure) president.

Ruling:

Yes. The Supreme Court affirmed the legitimacy of Arroyo's presidency, asserting that Estrada's
resignation was evident in his departure from Malacañang. Estrada's final statement acknowledged
Arroyo's oath-taking, emphasized leaving for peace and national healing, expressed gratitude for the
opportunity to serve, committed to facing future challenges, and called for reconciliation and solidarity
among supporters. The Court held that Estrada's resignation was clear and affirmed Arroyo's de jure
presidency.

Civil Liberties Union Vs. The Executive Secretary

Facts:

Cory Aquino issued EO 284 allowing Cabinet members, undersecretaries, and assistant secretaries to
hold other government positions. The petitioner challenged the constitutionality of EO 248, arguing that
"unless otherwise provided" in Section 13 of Article 7 refers only to provisions in the Constitution, such
as the Vice-President's appointment to the Cabinet and the Secretary of Justice's ex-officio membership
in the Judicial and Bar Council under Section 3 and 8 of Article 7, respectively.

Issue:

Whether EO 248 is Constitutional.

Ruling:

No. Section 13 of Article 7 specifies that the President, Vice-President, Cabinet members, and their
deputies or assistants should not hold any other office or employment during their tenure, unless
otherwise provided in the Constitution. The Court ruled that "unless otherwise provided" refers only to
constitutional provisions like the Vice-President's Cabinet appointment and the Secretary of Justice's role
in the Judicial and Bar Council. Thus, EO 284 allowing multiple government positions is deemed
unconstitutional.
Olaguer etal. v. Military Commission

Facts:

Petitioners, civilians charged with subversion, faced trial by Military Commission No. 34, created by the
Chief-of-Staff of the AFP. They were convicted and sentenced to death. Petitioners sought to enjoin the
military tribunal, arguing it was null and void. Respondents cited Aquino v. Military Commission No. 2,
asserting the constitutionality of military commissions even after the lifting of Martial Law.

Issue:

Whether the ruling in Aquino v. Military Commission should be abandoned or modified, considering the
change in circumstances with the lifting of Martial Law.

Held:

Yes. The Court held that the lifting of martial law rendered military tribunals void, as they were created
for that specific purpose. Citing dissenting views in Aquino v. MilComm, the Court emphasized that
civilians accused of civil offenses under general law are entitled to judicial trials. The Court declared that
precedent should yield when constitutionalism and the public interest demand it, emphasizing the
importance of correctness over precedent. Due process requires a trial by judicial process, and military
tribunals are not part of the Philippine judicial system.

GROUP 7 CASES

Province of North Cotabato v. Gov’t. of the RP Peace Panel on Ancestral Domain Judicial review/judicial
inquiry

Facts:

The cases involve the President's pursuit of the peace process amid armed conflict with the Moro Islamic
Liberation Front (MILF) in Mindanao. Petitioners sought disclosure of the MOA-AD between the
government and the MILF, alleging its unconstitutionality. Despite a temporary restraining order, various
parties challenged the MOA-AD's constitutionality and moved for disclosure. Respondents argued
mootness and moved for dismissal.

Issues:

Whether the petitions have complied with the procedural requirements for the
exercise of judicial review.
Whether the contents of the MOA-AD violated the Constitution and the laws

Ruling:

Yes. The SC ruled that the petitions complied with procedural requirements for judicial review. It stressed
that the alleged acts exceeding authority and violating duties under the Constitution and statutes
justified the necessity of judicial review. The Court acknowledged the standing of various petitioners,
including LGUs, taxpayers, and organizations.
Yes. The SC found several provisions in the MOA-AD inconsistent with the Constitution and laws. Notably,
it observed that the MOA-AD seemed to grant the Bangsamoro Juridical Entity (BJE) a status akin to an
associated state, contrary to constitutional principles. Emphasizing the need for clear distinctions
between amendments and revisions to the Constitution, the Court also highlighted conflicts with the
President's constitutional role as the sole representative of the country with foreign nations. The SC
declared the suspensive clause unconstitutional, as it assumed changes to the Constitution as certain,
limiting the President's power to propose amendments or revisions to Congress according to legal
procedures.

Zandueta v. de la Costa Effects of Declaration of Unconstitutionality

Facts:

Judge Francisco Zandueta held the position of judge of the Court of First Instance in Manila, initially
appointed in 1936. In 1937, he received a new ad interim appointment from the President, as the
Judicial Reorganization Law took effect. However, the Commission on Appointments disapproved of this
appointment in 1938. Zandueta sought reinstatement to his former post.

Issue:

Whether the petitioner, having accepted a new ad interim appointment and subsequently disapproved
by the Commission on Appointments, can question the constitutionality of the law that provided the
new appointment.

Ruling:

No. The petitioner, by accepting the new appointment, abandoned his old office. Having taken on the
responsibilities and salary of the new appointment and with the disapproval by the Commission on
Appointments, he cannot reclaim the old office or question the constitutionality of the law providing the
new appointment.

Bar Flunkers Case. March 1954. In the Matter of Petitions for Admission to the Bar of Unsuccessful
Candidates of 1946 to 1953. (In re: Cunanan, Resolution) Partial Unconstitutionality

Facts:

The Supreme Court, under the Rules of Court, required bar candidates to obtain a general average of
75%, without falling below 50% in any subject, for admission to the bar. Unsuccessful candidates who
scored slightly lower than those admitted agitated for a legislative change. In 1951, Congress passed
Senate Bill No. 12, reducing the passing rate to 70%. Seven SC members opposed the bill, and the
President vetoed it. Congress later passed Senate Bill No. 371, embodying similar provisions. The
President allowed it to become law on June 21, 1953, without a signature.

Issue:

Whether the Legislature has the authority to adjust the passing rate for admission to the bar.

Ruling:

No. The Legislature lacks the authority to adjust the passing rate for admission to the bar. The law in
question is deemed a judgment, and only the Supreme Court, not the Legislature, has the authority to
set such standards. While Bill 371 aimed to retroactively correct the deviation from the 75% rule since
1946, the SC, respecting the separation of powers, did not override the veto. Instead, Congress passed
Bill 371, suggesting a gradual increase in passing averages to align with the demands of the Executive
and Legislature.

GROUP 8 CASES

Perfecto vs. Meer Salaries of Judge

Facts:

Justice Gregorio Perfecto was assessed income tax on his salary as a member of the Supreme Court for
the year 1946. He paid the tax but contested its lawfulness, arguing that taxing judicial salaries would
violate the Constitution's prohibition against diminution (Sec. 9, Art. VIII, 1935 Constitution).

Issue:

Whether the imposition of income tax on the salary of a judge violates the constitutional prohibition
against diminution.

Held:

Yes. The imposition of income tax on judicial salaries violates the Constitution's prohibition against
diminution. The salaries of judges are not considered "income" subject to taxation under the Income Tax
Law. This interpretation aligns with the historical context when the law was first applied in the
Philippines in 1913 and the Federal principle known during the 1935 Constitutional Convention. The
undiminishable character of judicial salaries is a basic limitation imposed in the public interest,
safeguarding the independence of the judiciary.

Gaminde vs. COA Constitutional Commission Terms (Appointments)

Thelma P. Gaminde, appointed as an ad interim commissioner in June 1993, was initially informed that
her term would expire on February 2, 1999. In 1998, she sought clarification and received an advisory
opinion stating that her term would end in 2000. Relying on this, she continued in office beyond
February 2, 1999. Subsequently, the Commission on Audit (COA) disallowed the payment of salaries to
Gaminde and her coterminous staff, citing the expiration of their appointments.

Issue:

Whether Thelma P. Gaminde and her coterminous staff are entitled to receive their salaries despite the
expiration of their appointments on February 2, 1999.

Ruling:

Yes. The Court ruled that Gaminde's term as Commissioner, Civil Service Commission, expired on
February 2, 1999. However, since she served as a de facto officer in good faith until February 2, 2000, she
is entitled to receive her salary and other emoluments for the actual service rendered. Thus, the COA's
disallowance of salaries and emoluments beyond February 2, 1999, was considered erroneous.
GROUP 9 CASES

Pascual v. Hon. Provincial Board of Nueva Ecija Condonation Doctrine

Facts:

Arturo B. Pascual, petitioner-appellant, was elected mayor of San Jose, Nueva Ecija, in 1951 and
reelected in 1955. In 1956, the Acting Provincial Governor filed administrative charges against him,
including one for "Maladministrative, Abuse of Authority, and Usurpation of Judicial Functions." The
charge alleged that Pascual, during his first term, willfully assumed judicial powers by conducting a
preliminary investigation and reducing bail in a criminal case.

Issue:

Whether the Provincial Board of Nueva Ecija has jurisdiction to investigate the charge, considering it
involves alleged misconduct committed by Pascual during his prior term.

Ruling:

No. The Court ruled in favor of Pascual, stating that the Provincial Board lacked jurisdiction to investigate
the charge. It held that a municipal official cannot be disciplined for acts committed during a previous
term. Ergo, the Court ruled that offenses committed or acts done during a previous term generally do
not provide grounds for removal or disqualification from holding office for the term for which the officer
was elected or appointed. Therefore, the Court held that Pascual could not be disciplined for acts
committed during his prior term.

Morales vs Court of Appeals and Binay Jr. Abandonment of Condonation Doctrine

Facts:

Oscar Gonzales Malapitan, an elected public official, faced a criminal complaint for the alleged
anomalous use of his Priority Development Assistance Fund (PDAF) during his term as Caloocan City First
District Representative. The complaint, filed in 2015, included an administrative charge against other
officials but omitted Malapitan. In 2016, the Office of the Ombudsman sought to amend the complaint
to include Malapitan. The amendment was granted. Malapitan challenged this decision, invoking the
condonation doctrine, which shields elected officials from administrative liability for acts committed
during a prior term. The Court of Appeals ruled in favor of Malapitan, applying the condonation doctrine.

Issue:

Whether the condonation doctrine applies to shield Malapitan from administrative liability for alleged
misconduct during his prior term as Caloocan City First District Representative.

Ruling:

Yes. The Court of Appeals correctly applied the condonation doctrine, holding that Malapitan could not
be administratively charged for acts committed during his previous term as they were condoned by his
reelection. The abandonment of the condonation doctrine, effective April 12, 2016, does not
retroactively apply to cases filed before that date. Since Malapitan's alleged misconduct occurred in
2009, and he was reelected in 2010, the condonation doctrine still applies. The Court of Appeals did not
encroach on the powers of the Office of the Ombudsman when it enjoined further proceedings against
Malapitan, as administrative offenses do not prescribe, and the condonation doctrine was a valid
defense at the time the case was filed. The ruling absolves Malapitan of administrative liability but does
not affect the criminal complaint against him.

Rolando Layug vs. COMELEC

Facts:

Petitioner Rolando Layug filed a petition to disqualify Buhay Party-List from participating in the May 10,
2010 elections, alleging that it is an "extension of the El Shaddai" religious sect, making it ineligible
under constitutional and statutory provisions. Layug also sought to disqualify Brother Mike, a billionaire
real estate businessman and the spiritual leader of El Shaddai, from being its nominee, arguing that he
does not belong to the marginalized and underrepresented sector required for party-list nominees.

Issue:

Whether the House of Representatives Electoral Tribunal (HRET) has jurisdiction over the qualifications
of party-lists.

Ruling:

No. The House of Representatives Electoral Tribunal (HRET) does not have jurisdiction over the
qualifications of party-lists. Buhay Party-List, entitled to two seats in the House, had its first two
nominees elected, but Brother Mike, being the fifth nominee, did not secure a seat and did not become
a member of the House of Representatives. The HRET lacks jurisdiction over Brother Mike's
qualifications. Additionally, the jurisdiction to decide on the qualifications of Buhay Party-List rests with
the Commission on Elections (COMELEC), as mandated by the Party-List System Act, specifically Section
6, which grants the COMELEC the authority to remove or cancel the registration of any party-list
organization after due notice and hearing.

GROUP 10 CASES

Republic of the Philippines vs. Sandiganbayan

Facts:

Imelda R. Marcos, Irene Marcos-Araneta, Maria Imelda Marcos, and Ferdinand R. Marcos, Jr. filed a
motion for reconsideration challenging the July 15, 2003, decision that ordered the forfeiture of Swiss
deposits held in escrow at the Philippine National Bank (PNB). The amount involved was approximately
658,175,373 US dollars as of January 3, 2002. Imelda Marcos claimed the decision would prejudice her
ongoing criminal cases. Respondents Ferdinand, Jr. and Imee Marcos requested the decision be set aside,
urging a remand of the case to the Sandiganbayan. Irene Araneta, in her motion, reiterated previous
arguments and sought to overturn the July 15, 2003 decision.

Issue:

Whether the use of summary judgment in forfeiture proceedings constitutes a violation of due process.
Ruling:

No. As Respondent Marcoses argued that Republic Act No. 1379 (R.A. 1379) forbids summary judgment
in forfeiture cases, citing specific jurisdictional requirements, the Court found no violation of substantive
due process, stating that R.A. 1379 was not shown to be unfair or unreasonable. The forfeiture
proceedings were deemed civil in nature, contrary to the Marcoses' claim of a penal character.
Therefore, the Court ruled that the proceedings did not violate the substantive rights of the respondents.

Mabanag v. Lopez Vito Judicial review of amendments

Facts:

Three senators and eight representatives were proclaimed elected in the 1946 elections but were
suspended due to election irregularities. They were not allowed to participate in legislative activities,
including the passage of a resolution proposing an amendment to the Constitution. The absence of their
votes would result in an insufficient three-fourths majority needed for the amendment. Petitioners
argued that considering these members would have led to an inadequate vote.

Issue:

Whether the Court can take cognizance of the issue concerning the validity of the proposed
constitutional amendment.

Ruling:

No. The Court cannot take cognizance of the issue as it involves political questions, which are beyond the
judiciary's province unless explicitly conferred by constitutional or statutory provision. The doctrine is
based on the separation of powers. The case involves the highly political act of proposing constitutional
amendments by Congress, and judicial inquiry is less justified in the proposal's validity compared to the
ratification process. The efficacy of ratification is recognized as a political question. The Court deferred to
the political branches in matters involving constitutional amendments.

Lambino V. COMELEC
Facts:

Atty. Lambino and others initiated a signature campaign for a constitutional change, gathering alleged
signatures representing 12 percent of voters. They filed a petition with COMELEC seeking a plebiscite to
ratify their proposed constitutional amendments. The changes aimed to shift from a Bicameral-
Presidential to a Unicameral-Parliamentary system.

Issue:

Whether the Lambino group's initiative is valid.

Ruling:

The initiative was deemed invalid. It failed to comply with Sec. 2, Art. XVII of the Constitution, which
requires the proposal to be directly made by the people. The Court emphasized that the entire proposal
should be authored and signed by the people, with no representation allowed. Additionally, the proposal
must be embodied in the petition. In this case, the full text of the proposed amendments was neither in
the petition nor attached to it. The initiative was considered a revision, not an amendment, as it sought a
fundamental change in the form of government. The Court concluded that the initiative violated
constitutional provisions, rendering it invalid.

Orap vs. Sandiganbayan

Facts:

Tanodbayan Special Prosecutor Rodolfo B. Aquino filed three informations before the Sandiganbayan,
charging Judge Vicente S. Orap and his clerk of court, Melanio B. Fernandez, with violation of Section
3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act). The charges accused them of
unlawfully receiving money from various individuals. Judge Orap filed a motion to quash, claiming the
Tanodbayan lacked authority over judges and judicial staff.

Issue:

Whether the Tanodbayan has the authority to conduct preliminary investigations, file informations, and
prosecute criminal cases against judges and their judicial staff.

Ruling:

Yes. The Tanodbayan serves as both an ombudsman and a prosecutor. While its investigatory powers are
limited to administrative agencies under Section 9(a) of the law, its authority as a prosecutor is primary
and without exceptions. Sections 17 and 19 of P.D. 1607 define the Tanodbayan's powers, allowing
exclusive authority to conduct preliminary investigations, file informations, and control prosecutions in
cases cognizable by the Sandiganbayan. Even judges and court personnel fall under the Tanodbayan's
investigatory power. Failure to allow investigations against them would hinder justice. The filed
informations met legal requirements, carrying the necessary certifications and approvals. As the charges
fall within the Sandiganbayan's jurisdiction under Section 4 of P.D. 1606, the court validly acquired
jurisdiction over the case.