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The Committee on Good Government and Public Accountability of the House of Representatives conducted an inquiry in aid of legislation pertaining to…

2026 Bar Exam · Political & Public International Law · Question 5 · Essay

The question

The Committee on Good Government and Public Accountability of the House of Representatives conducted an inquiry in aid of legislation pertaining to the use by the Provincial Government of Cagayan of its shares from the excise taxes on locally manufactured Virginia-type cigarettes for a purpose other than that provided in Republic Act No. 7171. Due to the evasive answers of the invited provincial government officials (officials) to questions, they were cited in contempt and ordered detained. The officials filed a Petition for Habeas Corpus before the Court of Appeals (CA). After several hearings, the CA issued a writ of habeas corpus and granted the officials’ motion for provisional release. The legislators who were dismayed by the CA’s actions issued a show cause order against the three Justices of the CA Division who issued the writ and ordered the officials’ provisional release. The CA Justices were directed to explain why they should not be cited in contempt by the House of Representatives. May the House of Representatives cite the CA Justices in contempt? Explain.

Held

No, the House of Representatives may not cite the Court of Appeals Justices in contempt, under Article VIII, Sections 1 and 11, and Article VI, Section 21 of the 1987 Constitution.

Explanation

The Constitution vests judicial power exclusively in the Supreme Court and lower courts, which includes the duty to settle controversies and review government actions for grave abuse of discretion. Judges and justices hold office during good behavior and are subject only to discipline by the Supreme Court en banc, not by the legislative branch. The power of the House of Representatives to conduct inquiries in aid of legislation is subject to respecting the rights of persons involved. While the House has the power to punish for contempt to preserve its functions, this power does not extend to judicial officers performing their judicial duties, as their discipline and accountability lie within the judiciary itself.

Application to the facts

In this case, the Court of Appeals Justices issued a writ of habeas corpus and granted provisional release to the provincial government officials. These acts are judicial functions within the scope of their judicial power. The House of Representatives, through its Committee on Good Government and Public Accountability, may conduct inquiries and punish contempt to preserve its legislative functions, but it cannot extend this power to cite judicial officers in contempt for acts done in the exercise of their judicial duties. The Constitution clearly assigns the discipline of judges and justices to the Supreme Court en banc, not to the legislature. Therefore, the House's show cause order against the CA Justices for contempt over their judicial acts is beyond its constitutional authority.

  • a constitutional provision is among the sources and controls over any conflicting statute
This is general legal information, not legal advice.