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Osmeña, Jr. vs Pendatun, et al. L-17144 October 28, 1960

Bengzon, J.

FACTS:

On June 23, 1960, Congressman Sergio Osmeña, Jr. delivered a speech entitled “A Message to
Garcia”. In the said speech, he disparaged then President Carlos Garcia and his administration
for bribery (selling things such as pardons at premium prices).

Subsequently, House Resolution No. 59 was passed by the lower house in order to investigate the
charges made by Osmeña during his speech and that if his allegations were found to be baseless
and malicious, he may be subjected to disciplinary actions by the lower house.

Upon investigation by the Special Committee tasked to look into Osmeña’s imputations, House
Resolution No. 175 was passed finding Osmeña guilty of serious disorderly behavior, thus
suspending him for 15 months.

Osmeña then questioned the validity of the said resolution before the Supreme Court by averring
that the resolution violates his parliamentary immunity for speeches delivered in
Congress. Congressman Salipada Pendatun filed an answer where he averred that the Supreme
Court has no jurisdiction over the matter and Congress has the power to discipline its members.

ISSUE: Whether or not the House can suspend Osmeña for disorderly behavior?

HELD/ RATIO: Yes. The House has jurisdiction over the case, and it is not subject to judicial
review.

The Court posits that the House is the sole judge of what constitutes disorderly behavior, not only
because the Constitution has conferred jurisdiction upon it, but also because the matter depends
mainly on factual circumstances of which the House knows best but which can not be depicted in
black and white for presentation to, and adjudication by the Courts. The theory of separation of
powers demands that each department has exclusive cognizance of matters within its jurisdiction
and is supreme within its own sphere. The House has exclusive power and the Courts have no
jurisdiction to interfere.

Additionally, Osmeña’s invocation of parliamentary immunity is not justified. Though immunity

guarantees the legislator complete freedom of expression without fear of being made responsible
in criminal or civil actions before the courts or any other forum outside the Hall of Congress,
members of the Congress may still be questioned by Congress itself. This section does not protect
members of the Congress from responsibility before the legislative body itself whenever his words
and conduct are considered by the latter disorderly or unbecoming a member thereof.

Therefore, Osmeña’s petition is dismissed.