The determination of sufficiency of form and substance of an impeachment complaint is an exponent of the express constitutional grant of rule-making powers of the House of Representatives

Petitioner further claims that public respondent failed to ascertain the sufficiency of form and substance of the complaints on the basis of the standards set by the Constitution and its own Impeachment Rules.[35]

The claim fails.

The determination of sufficiency of form and substance of an impeachment complaint is an exponent of the express constitutional grant of rule-making powers of the House of Representatives which committed such determinative function to public respondent.  In the discharge of that power and in the exercise of its discretion, the House has formulated determinable standards as to the form and substance of an impeachment complaint.  Prudential considerations behoove the Court to respect the compliance by the House of its duty to effectively carry out the constitutional purpose, absent any contravention of the minimum constitutional guidelines.

Contrary to petitioner’s position that the Impeachment Rules do not provide for comprehensible standards in determining the sufficiency of form and substance, the Impeachment Rules are clear in echoing the constitutional requirements and providing that there must be a “verified complaint or resolution,”[36] and that the substance requirement is met if there is “a recital of facts constituting the offense charged and determinative of the jurisdiction of the committee.”[37]

          Notatu dignum is the fact that it is only in the Impeachment Rules where a determination of sufficiency of form and substance of an impeachment complaint is made necessary.  This requirement is not explicitly found in the organic law, as Section 3(2), Article XI of the Constitution basically merely requires a “hearing.”[38]  In the discharge of its constitutional duty, the House deemed that a finding of sufficiency of form and substance in an impeachment complaint is vital “to effectively carry out” the impeachment process, hence, such additional requirement in the Impeachment Rules.

          Petitioner urges the Court to look into the narration of facts constitutive of the offenses vis-à-vis her submissions disclaiming the allegations in the complaints.

          This the Court cannot do.

          Francisco instructs that this issue would “require the Court to make a determination of what constitutes an impeachable offense.  Such a determination is a purely political question which the Constitution has left to the sound discretion of the legislature.  Such an intent is clear from the deliberations of the Constitutional Commission.  x x x x Clearly, the issue calls upon this court to decide a non-justiciable political question which is beyond the scope of its judicial power[.]”[39]  Worse, petitioner urges the Court to make a preliminary assessment of certain grounds raised, upon a hypothetical admission of the facts alleged in the complaints, which involve matters of defense.

http://sc.judiciary.gov.ph/jurisprudence/2011/february2011/193459.htm

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About Erineus

Born on December 28, 1965, Surallah, South Cotabato, Southern Mindanao, Philippines.
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