CASE DIGESTS

Garces vs. Estenso Facts: The case is about the constitutionality of four resolutions of the barangay council of Valencia, Ormoc City, regarding the acquisition of the wooden image of San Vicente Ferrer to be used in the celebration of his annual feast day. That issue was spawned by the controversy as to whether the parish priest or a layman should have the custody of the image. On March 23, 1976, the said barangay council adopted Resolution No. 5, "reviving the traditional socio-religious celebration" every fifth day of April "of the feast day of Señor San Vicente Ferrer, the patron saint of Valencia". Issue: Is the holding of fiesta and having a patron saint for the barrio, valid and constitutional? Held: Yes. The wooden image was purchased in connection with the celebration of the barrio fiesta honoring the patron saint, San Vicente Ferrer, and not for the purpose of favoring any religion nor interfering with religious matters or the religious be

FACTS: Fernando Poe Jr. (FPJ) filed an election protest at the Presidential Electoral Tribunal (PET) against the proclaimed winner of the 2004 presidential elections. During the pendency of the case, FPJ died. His widow, Susan Roces, claimed before the PET that there was an urgent need for her to substitute her husband in the election protest that he had filed as it is of paramount interest to the Filipino people. ISSUE: May the widow substitute/intervene for the protestant who died during the pendency of the latter’s presidential protest case? RULING: No. The fundamental rule applicable in a presidential election protest is Rule 14 of the PET Rules. It provides that only the registered candidate for President or Vice President of the Philippines who has received the second or third highest number of votes may timely contest the election of the proclaimed winner. Furthermore, a public office is personal to the public officer and is not a property capable of being transmitted to his hei

FACTS: Petitioners questioned the jurisdiction of the COMELEC in taking cognizance of and deciding the citizenship issue affecting Fernando Poe Jr. They asserted that under Section 4(7) , Article VII of the 1987 Constituition, only the Supreme Court had original and exclusive jurisdiction to resolve the basic issue of the case. ISSUE: As the Presidential Electoral Tribunal (PET) , does the Supreme Court have jurisdiction over the qualifications of presidential candidates? RULING: No. An examination of the phraseology in Rule 12, 13, and Rule 14 of the "Rules of the Presidential Electoral Tribunal," promulgated by the Supreme Court on April 1992 categorically speak of the jurisdiction of the tribunal over contests relating to the election, returns and qualifications of the "President" or "Vice-President", of the Philippines, and not of "candidates" for President or Vice-President. A quo warranto proceeding is generally defined as being an action

FACTS: Congress enacted RA 8436 authorizing COMELEC to use an automated election system for the process of voting, counting of votes and canvassing/consolidation the results of national and local elections. COMELEC subsequently approved Resolution 6712 adopting the policy that the precinct election results of each city and municipality shall be immediately transmitted electronically in advance to the COMELEC in Manila. Petitioners in this case questioned, among others, the Constitutionality of the quickcount as being pre-emptive of the authority vested in Congress to canvass the votes for the President and Vice-President under Article VII, Section 4 of the 1987 Constitution. ISSUE: Can the COMELEC conduct “unofficial” tabulation of presidential election results based on a copy of the election returns? RULING: No. The assailed resolution usurps, under the guise of an “unofficial” tabulation of election results based on a copy of the election returns, the sole and exclusive authority of

KMU vs. NEDA , GR no. 167798 , April 19, 2006 FACTS: In April 13, 2005, President Gloria Macapagal – Arroyo issued Executive Order 420 requiring all government agencies and government-owned corporations to streamline and harmonize their Identification Systems. The purposes of the uniform ID data collection and ID format are to reduce costs, achieve efficiency and reliability and ensure compatibility and provide convenience to the people served by government entities. Petitioners allege that EO420 is unconstitutional because it constitutes usurpation of legislative functions by the executive branch of the government. Furthermore, they allege that EO420 infringes on the citizen’s rights to privacy. ISSUE: In issuing EO 420, did the president make, alter or repeal any laws? RULING: Legislative power is the authority to make laws and to alter or repeal them. In issuing EO 420, the President did not make, alter or repeal any law but merely implemented and executed existing laws. EO 420 r

Senate vs. Ermita , GR 169777, April 20, 2006 FACTS: This is a petition for certiorari and prohibition proffer that the President has abused power by issuing E.O. 464 “Ensuring Observance of the Principles of Separation of Powers, Adherence to the Rule on Executive Privilege and Respect for the Rights of Public Officials Appearing in Legislative Inquiries in Aid of Legislation Under the Constitution, and for Other Purposes”. Petitioners pray for its declaration as null and void for being unconstitutional. In the exercise of its legislative power, the Senate of the Philippines, through its various Senate Committees, conducts inquiries or investigations in aid of legislation which call for, inter alia, the attendance of officials and employees of the executive department, bureaus, and offices including those employed in Government Owned and Controlled Corporations, the Armed Forces of the Philippines (AFP), and the Philippine National Police (PNP). The Committee of the Senate issued inv