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
"The judicial power shall be vested in one Supreme Court and in such lower courts as may be established by law. Judicial power includes the duty of the courts of justice to settle actual controversies involving rights which are legally demandable and enforceable, and 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."
"The Members of the Supreme Court and judges of the lower court shall hold office during good behavior until they reach the age of seventy years or become incapacitated to discharge the duties of their office. The Supreme Court en banc shall have the power to discipline judges of lower courts, or order their dismissal by a vote of majority of the Members who actually took part in the deliberations on the issues in the case and voted in thereon."
"The Senate or the House of Representatives or any of its respective committees may conduct inquiries in aid of legislation in accordance with its duly published rules of procedure. The rights of persons appearing in, or affected by, such inquiries shall be respected."
Laws retrieved
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- Section 11, The 1987 Constitution of the Republic of the Philippines
- Section 1, The 1987 Constitution of the Republic of the Philippines
- Section 21, The 1987 Constitution of the Republic of the Philippines
- Section 5, The 1987 Constitution of the Republic of the Philippines
"In the same connection, we may say further that the court need not inquire into the correctness of the facts recited in the original resolution of the House of Representatives punishing the petitioner for contempt. We cannot, however, concur with the statement of the Attorney-General that, because of the separation of powers, the courts have no jurisdiction to entertain this petition. Where the liberty of the citizen is concerned, the legality of the action taken by the legislative body in punishing for contempt is a proper subject for inquiry on _habeas corpus_. (Zagala _vs._ Ilustre , 48 Phil., 282; Lorenzo vs…
Cases retrieved
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