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DefensorSantiago vs. Guingona G.R. No. 134577, November 18, 1998 Facts: During the first regular session of the eleventh Congress, Senator Fernan was declared the duly elected President of the Senate by a vote of 20 to 2. Senator Tatad manifested that, with the agreement of Senator Santiago, allegedly the only other member of the minority, he was assuming the position of minority leader. He explained that those who had voted for Senator Fernan comprised the majority, while only those who had voted for him, the losing nominee, belonged to the minority. Senator Flavier manifested that the senators belonging to the LakasNUCDUMDP Party numbering 7 and, thus, also a minority had chosen Senator Guingona as the minority leader. Thereafter, the majority leader informed the body that he was in receipt of a letter signed by the 7 LakasNUCDUMDP senators, stating that they had elected Senator Guingona as the minority leader. By virtue thereof, the Senate President formally recognized Senator Guingona as the minority leader of the Senate. Senators Santiago and Tatad filed a petition for quo warranto, alleging that Senator Guingona had been usurping, unlawfully holding and exercising the position of Senate minority leader, a position that, according to them, rightfully belonged to Senator Tatad. Issues: (1) Whether or not the Court has jurisdiction over the petition (2) Whether or not there is an actual violation of the Constitution Held: Regarding the first issue, jurisdiction over the subject matter of a case is determined by the allegations of the complaint or petition, regardless of whether the petitioner is entitled to the relief asserted. In light of the allegations of the petitioners, it is clear that the Court has jurisdiction over the petition. It is well within the power and jurisdiction of the Court to inquire whether indeed the Senate or its officials committed a violation of the Constitution or gravely abused their discretion in the exercise of their functions and prerogatives. However, the interpretation proposed by petitioners finds no clear support from the Constitution, the laws, the Rules of the Senate or even from practices of the Upper House. The

Defensor v. Guingona

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DefensorSantiago vs. Guingona G.R. No. 134577, November 18, 1998Facts During t!e "rst regu#ar session of t!e e#event! $ongress, Senator Fernan %as &ec#are& t!e &u#' e#ecte& (resi&ent of t!e Senate b' a vote of )* to ). Senator +ata&manifeste& t!at, %it! t!e agreement of Senator Santiago, a##ege' t!e on#' ot!er member of t!e minorit', !e %as assuming t!e ,osition of minorit' #ea&er. -e e.,#aine& t!at t!ose %!o !a& vote& for Senator Fernan com,rise& t!e ma/orit', %!i#e on#' t!ose %!o !a& vote& for !im, t!e #osing nominee, be#onge& to t!e minorit'. Senator F#avier manifeste& t!at t!e senators be#onging to t!e 0a1asN2$D324D( (art' numbering 7 an&, t!us, a#so a minorit' !a& c!osen Senator Guingona as t!e minorit' #ea&er. +!ereafter, t!e ma/orit' #ea&er informe& t!e bo&' t!at !e %as in recei,t of a #etter signe& b' t!e 7 0a1asN2$D24D( senators, stating t!at t!e' !a& e#ecte& Senator Guingona as t!e minorit' #ea&er. 5' virtue t!ereof, t!e Senate (resi&ent forma##' recogni6e& Senator Guingona as t!e minorit' #ea&er of t!e Senate. Senators Santiago an& +ata& "#e& a ,etition for 7uo %arranto, a##eging t!at Senator Guingona !a& been usur,ing, un#a%fu##' !o#&ing an& e.ercising t!e ,osition of Senate minorit' #ea&er, a ,osition t!at, accor&ing to t!em, rig!tfu##' be#onge& to Senator +ata&. 8ssues 91: ;!et!er or not t!e $ourt !as /uris&iction over t!e ,etition 9): ;!et!er or not t!ere is an actua# vio#ation of t!e $onstitution-e#& Regar&ing t!e "rst issue, /uris&iction over t!e sub/ect matter of a case is &etermine& b' t!e a##egations of t!e com,#aint or ,etition, regaress of %!et!er t!e ,etitioner is entit#e& to t!e re#ief asserte&. 8n #ig!t of t!e a##egations of t!e ,etitioners, it is c#ear t!at t!e $ourt !as /uris&iction over t!e ,etition. 8t is %e## %it!in t!e ,o%er an& /uris&iction of t!e $ourt to in7uire %!et!er in&ee& t!e Senate or its o