[20] BAGULAT v ALVAREZ o 252 voted for Speaker Alvarez, 8 for Rep. Baguilat, 7 for Rep.
G.R. No. 227757 | July 25, 2017 | Ponente: Perlas-Bernabe, J.
cestan
PETITIONERS: Representative Teddy Brawner Baguilat, Jr., Representative Edcel C.
Lagman, Representative Raul A. Daza, Representative Edgar R. Erice, Representative
Emmanuel A. Billones, Representative Tomasito S. Villarin, And Representative
Gary C. Alejano
RESPONDENTS: Speaker Pantaleon D. Alvarez, Majority Leader Rodolfo C.
Fariñas, And Representative Danilo E. Suarez
TOPIC: Legislature
CASE SUMMARY: Petitioners contest the election of Rep. Suarez as Minority Leader
of the HoR, and thus filed a petition for mandamus insisting that Rep. Baguilat should
be named Minority Leader instead. The SC held that mandamus is not a proper remedy
because the Petitioners have no legal right over the reliefs sought. Also, the
Constitution vests in the HoR the sole authority to determine the rules of its
proceedings and the Court has no authority to interfere and unilaterally intrude into
that exclusive realm, without running afoul of Constitutional principles that it is bound
to protect and uphold. The method of choosing who will be the officers of the HoR is
merely a derivative of the exercise of the prerogative conferred by the constitution.
Therefore, such method must be prescribed by the HoR itself, and not by the Court.
DOCTRINE: The Speaker of the House of Representatives shall be elected by a
majority vote of its entire membership. Said provision also states that the House of
Representatives may decide to have officers other than the Speaker, and that the
method and manner as to how these officers are chosen is something within its sole
control. Section 16(3), Article VI of the Constitution vests in the House of
Representatives the sole authority to, inter alia, “determine the rules of its
proceedings.”
FACTS:
 July 26, 2016: The House of Representatives (HoR) conducted an Election for
Speakership.
Suarez, 21 abstained, and 1 registered a no vote. Speaker Alvarez
was duly elected the Speaker of the HoR of the 17 th Congress.
 July 27: those who did not vote for Speaker Alvarez (including the 21
abstentionists) convened and elected Rep. Suarez as the Minority Leader. On
Aug 15, Rep. Fariñas moved for the recognition of Rep. Suarez as the
Minority Leader, which Rep. Lagman opposed on the grounds that:
o Rep. Suarez was a member of the Majority since he voted for
Speaker Alvarez;
o The abstentionists who consisted most of the votes for Rep. Suarez
should have been considered as independent members of the
House, not part of the Minority.
 Rep. Lagman’s opposition was overruled, and Rep. Suarez
was officially recognized as Minority Leader.
 Petitioners filed the instant petition for Mandamus, insisting that Rep.
Baguilat should be recognized as Minority Leader because it is a long-
standing tradition of the HoR to automatically make Minority Leader the
person who garners the 2nd highest vote, and because of the irregularities
attending the election of Rep. Suarez.
ISSUES and RULING:
 WON respondents may be compelled via a writ of mandamus to recognize Rep.
Baguilat as the Minority Leader of the House of Representatives? – NO
Subsequently, WON petitioners may be considered as the only legitimate
members of the House Minority? – NO
 Prior to the election, Rep. Fariñas articulated that:
o (a) all those who vote for the winning Speaker shall belong to the
Majority and those who vote for other candidates shall belong to the
Minority;
o (b) those who abstain from voting shall likewise be considered part
of the Minority; and
o (c) the Minority Leader shall be elected by the members of the
Minority.
  This interpretation went unopposed therefore the
Elections proceeded.
 Petitioners question Rep. Fariñas’ interpretation of the rules, but the foregoing
circumstances would show that the HoR had effectively adopted Rep. Fariñas’
proposal anent the new rules regarding the membership of the Minority, as
well as the process of determining who the Minority Leader would be.
o This deviation by the Lower House from the aforesaid rules is not
averse to the Constitution.
  Section 16 (1), Article VI of the 1987 Constitution: “The Senate shall elect its
President and the HoR, its Speaker, by a majority vote of all its respective
PROVISIONS:
Members. Each house shall choose such other officers as it may deem
necessary.”  Section 16 (1), Article VI of the 1987 Constitution: “The Senate shall elect its
o While the Constitution is explicit on the manner of electing a House President and the HoR, its Speaker, by a majority vote of all its respective
Speaker, it is, however, dead silent on the manner of selecting the Members. Each house shall choose such other officers as it may deem
other officers of the Lower House. necessary.”
o All that the Charter says is that “each House shall choose such other
officers as it may deem necessary.”
 As such, the method of choosing who will be such other
officers is merely a derivative of the exercise of the
prerogative conferred by the constitution. Therefore, such
method must be prescribed by the HoR itself, and not by
the Court.
 Section 16 (3) vests in the HoR the sole authority to, inter alia, “determine
the rules of its proceedings.” These legislative rules, unlike statutory laws,
do not have the imprints of permanence and obligatoriness during their
effectivity.
o In fact, they are subject to revocation, modification or waiver at the
pleasure of the body adopting them. Being merely matters of
procedure, their observance are of no concern to the courts.
 General rule: the Court has no authority to interfere and unilaterally intrude
into that exclusive realm, without running afoul of Constitutional principles
that it is bound to protect and uphold.
o Exception: grave abuse of discretion  the judiciary is the final
arbiter on the question of whether or not a branch of government or
any of its officials has acted without jurisdiction or in excess of
jurisdiction or so capriciously as to constitute an abuse of discretion
amounting to excess of jurisdiction. This is not only a judicial power
but a duty to pass judgment on matters of this nature.
 Court is hard-pressed to find any attending grave abuse of discretion which
would warrant its intrusion in this case.
 This case concerns an internal matter of a coequal, political branch of
government which, absent any showing of grave abuse of discretion, cannot
be judicially interfered with.
o It would be an unwarranted invasion of the prerogative of a coequal
department for this Court either to set aside a legislative action as
void only because it thinks that the House has disregarded its own
rules of procedure, or to allow those defeated in the political arena
to seek a rematch in the judicial forum when petitioners can find
their remedy in that department itself.

DISPOSITIVE: WHEREFORE, the petition is DISMISSED.