Facts
- **Petitioner**: Ma. Merceditas N. Gutierrez, then Ombudsman of the Philippines.
- **Respondents**: House of Representatives Committee on Justice, Risa Hontiveros-Baraquel, Danilo D. Lim, Felipe Pestaño, Evelyn Pestaño, Renato M. Reyes, Jr., Mother Mary John Mananzan, Danilo Ramos, Atty. Edre Olalia, Ferdinand R. Gaite, James Terry Ridon, and Feliciano Belmonte, Jr.
- **Background**: Two separate impeachment complaints were filed against Gutierrez before the House of Representatives, alleging betrayal of public trust and culpable violation of the Constitution. The complaints were referred to the House Committee on Justice for determination of sufficiency in form and substance.
- **Procedural Context**: On August 3, 2010, the House Committee on Justice found both complaints sufficient in form. On August 11, 2010, it found them sufficient in substance and proceeded to hear the complaints simultaneously. Gutierrez filed a petition for certiorari and prohibition with the Supreme Court, challenging the constitutionality of the House Committee's actions, particularly the simultaneous processing of two impeachment complaints.
- **Key Allegation**: Gutierrez argued that the simultaneous referral and consideration of two impeachment complaints violated the constitutional rule under Article XI, Section 3(5) of the 1987 Philippine Constitution, which states that "no impeachment proceedings shall be initiated against the same official more than once within a period of one year."
Issues
1. **Whether the Supreme Court has jurisdiction** to review the actions of the House Committee on Justice in impeachment proceedings.
2. **Whether the simultaneous referral and consideration** of two impeachment complaints against Gutierrez constituted a violation of Article XI, Section 3(5) of the 1987 Constitution, which prohibits the initiation of impeachment proceedings against the same official more than once within a one-year period.
3. **Whether the House Committee on Justice committed grave abuse of discretion** in processing the impeachment complaints.
Doctrines Held
- **Judicial Review of Impeachment Proceedings**:
- The Supreme Court has jurisdiction to review impeachment proceedings to determine whether constitutional provisions, such as Article XI, Section 3(5), have been violated. Impeachment is a political process, but the Court can intervene when there is a clear violation of constitutional mandates or grave abuse of discretion.
- The Court clarified that its role is limited to ensuring compliance with constitutional requirements and does not extend to interfering with the political discretion of the House of Representatives unless there is a clear constitutional violation.
- **Interpretation of Article XI, Section 3(5)**:
- The constitutional prohibition that "no impeachment proceedings shall be initiated against the same official more than once within a period of one year" refers to the **filing** of an impeachment complaint with the House of Representatives, not the referral or processing by the Committee on Justice.
- The Court held that the initiation of impeachment proceedings occurs when a verified complaint is filed and referred to the House Committee on Justice for action. The simultaneous referral of two complaints does not constitute multiple initiations of impeachment proceedings, as long as only one impeachment case proceeds to trial in the Senate within the one-year period.
- **No Grave Abuse of Discretion**:
- The House Committee on Justice did not commit grave abuse of discretion by simultaneously considering two impeachment complaints. The Court found that the Committee’s actions were within its discretion under the House Rules of Procedure in Impeachment Proceedings, which allow for the consolidation or simultaneous consideration of multiple complaints to determine sufficiency in form and substance.
- The constitutional one-year bar applies to the actual transmission of the Articles of Impeachment to the Senate for trial, not to the preliminary stages of processing complaints in the House.
- **Due Process in Impeachment**:
- The Court emphasized that impeachment proceedings must adhere to due process, but the determination of sufficiency in form and substance by the House Committee is a preliminary step and does not yet constitute the full impeachment process. Gutierrez’s rights to due process were not violated at this stage.
Summary of the Ruling
The Supreme Court
**dismissed** Gutierrez’s petition, ruling that the House Committee on Justice did not violate the Constitution by simultaneously processing two impeachment complaints. The Court clarified that the one-year bar under Article XI, Section 3(5) pertains to the initiation of an impeachment proceeding, which is defined as the filing of a verified complaint and its referral to the Committee. The simultaneous consideration of multiple complaints does not breach this provision, as only one impeachment case may proceed to the Senate for trial within a year. The Court found no grave abuse of discretion in the Committee’s actions and affirmed that its jurisdiction in impeachment cases is limited to ensuring constitutional compliance.
**Citation**:[](https://lawphil.net/judjuris/juri2011/feb2011/gr_193459_2011.html)[](https://lawphil.net/judjuris/juri2011/mar2011/gr_193459_2011.html)
This summary is based on the provided reference and general principles of Philippine jurisprudence. For a detailed reading, refer to the full text of the decision at https://lawphil.net/judjuris/juri2011/feb2011/gr_193459_2011.html.
Generated by Grok AI app, May 31, 2025, upon request of Atty. Manuel Laserna Jr.
