These cases reinforce the principle that even “political questions” within the domain of the legislature may be reviewed by the Supreme Court when grave abuse of discretion is alleged.
🔍 Landmark Jurisprudence Confirming Judicial Review of Legislative Acts for Grave Abuse of Discretion
🏛 1. Tañada v. Angara, G.R. No. 118295, May 2, 1997, 272 SCRA 18
- Context: Constitutionality of the Senate’s concurrence in the WTO Agreement.
- Ruling: Dismissed petition but affirmed the Supreme Court’s jurisdiction to review congressional acts for grave abuse of discretion.
- Doctrine:
“The Court's power under Article VIII, Section 1, paragraph 2 of the Constitution includes the authority to determine whether there has been grave abuse of discretion… even in ‘political questions.’”
🏛 2. Neri v. Senate Committees, G.R. No. 180643, March 25, 2008
- Context: Senate found NEDA Secretary Neri in contempt for not answering questions during the NBN-ZTE hearings.
- Ruling: The contempt order was nullified. The Court ruled that the Senate committed grave abuse of discretion for failing to follow its own rules and violating due process.
- Doctrine:
“Where the congressional inquiry has not complied with its own published rules or infringed fundamental rights, the courts can intervene via certiorari.”
🏛 3. Senator Miriam Defensor Santiago v. Senate of the Philippines (Guingona), G.R. No. 134577, November 18, 1998, 298 SCRA 756
- Context: Senator Santiago contested the recognition of Senator Guingona as the Senate Minority Leader, alleging procedural irregularities and partisan manipulation.
- Ruling: Dismissed on procedural grounds, but the Court reaffirmed its authority to review grave abuse of discretion in internal legislative matters.
- Doctrine:
“[T]he political question doctrine does not apply when there is clear showing of grave abuse of discretion by any government branch.”
- Significance: Although a non-interventionist ruling, it expressly recognized that Senate leadership decisions, if exercised arbitrarily, may be reviewed.
🏛 4. Villarosa v. HRET, G.R. No. 133469, November 3, 1998, 298 SCRA 337
- Context: A challenge to an HRET decision allegedly rendered without quorum and proper evidence.
- Ruling: Petition was granted. The Court held that the HRET, though an independent constitutional body, was not exempt from review when acting with grave abuse of discretion.
- Doctrine:
“Acts of constitutional bodies are subject to judicial scrutiny if performed with grave abuse of discretion amounting to lack or excess of jurisdiction.”
⚖️ Core Legal Doctrine
Under Article VIII, Section 1 (2) of the 1987 Constitution:
“Judicial power includes the duty of the courts… to determine whether or not there has been a grave abuse of discretion amounting to lack or excess of jurisdiction on the part of any branch or instrumentality of the Government.”
Definition of Grave Abuse of Discretion:
“Such capricious and whimsical exercise of judgment as is equivalent to lack of jurisdiction; … so patent and gross as to amount to an evasion of a positive duty or virtual refusal to perform the duty enjoined by law.”
✅ Implications for Impeachment Jurisdiction
Although the Senate sits as the Impeachment Court under Article XI, Section 3 of the Constitution, it is not immune from judicial scrutiny. The Supreme Court will not interfere with merits or political wisdom but **may correct actions that:
- Violate due process (e.g., illegal contempt or subpoenas),
- Ignore mandatory constitutional or procedural rules,
- Are patently arbitrary, capricious, or without jurisdiction.
