Francisco vs. House of Representatives

GR 160261
November 10, 2003
Petitioners: It's a compiled case so there are a LOT!

Facts: The 12th Congress of the House of Representatives adopted and approved the Rules of Procedure in Impeachment Proceedings which defined ‘initiated’ as to be counted against the one-year time bar rule, only on the day that the Committee on Justice finds the case against the official as sufficient in substance. On 2 June 2003, President Estrada filed an impeachment complaint against Chief Justice Davide but was found to be insufficient in substance. The following day, the second impeachment complaint was filed against Chief Justice Davide., founded on the alleged results of the legislative inquiry initiated by the lower House.

Issue: Is the second impeachment barred by the one-year time bar rule?

Held: Yes. The second impeachment complaint filed against the Chief Justice is barred. Article 11, Sec 3, par. 5 explicitly ordains that ‘no impeachment proceedings shall be initiated against the same official more than once within a period of one year’. Whenever possible, the words used in the Constitution should be given their ordinary meaning, verba legis. Initiate must be understood in its ordinary, plain meaning, which means, to begin, to commence, to set going. Hence an impeachment is initiated upon the filing of a complaint. When there is ambiguity, ratio legis et anima, meaning the Constitution should be interpreted in accordance with the intent of the framers which is to prevent too frequent harassment against the impeachable officer, and to allow the legislature to do its principal task, legislation.