Primary Holding

The Supreme Court declared Section 14 of the People's Court Act unconstitutional, as it violates the constitutional provisions on the appointment and qualifications of Supreme Court Justices and undermines the independence of the judiciary.

Background

The case arose from a motion filed by Jorge B. Vargas, challenging the constitutionality of Section 14 of the People's Court Act. This provision disqualified certain Supreme Court Justices from participating in treason cases related to the Japanese occupation, allowing the President to designate lower court judges to temporarily sit in the Supreme Court.

Facts

• 1. Section 14 of the People's Court Act disqualifies Supreme Court Justices who held office under the Japanese-sponsored Philippine Executive Commission or the Philippine Republic from sitting in treason cases. It also allows the President to designate lower court judges to temporarily sit in the Supreme Court to form a quorum or render judgment in such cases.

Arguments of the Petitioners

• 1. The petitioner argued that Section 14 violates the Constitution by: (a) adding qualifications for Supreme Court Justices not found in the Constitution; (b) authorizing the appointment of Justices without the required qualifications; (c) removing Justices from office without impeachment; (d) bypassing the Commission on Appointments; (e) creating two Supreme Courts; (f) impairing the rule-making power of the Supreme Court; (g) being a bill of attainder; (h) denying equal protection of the laws; (i) being an ex post facto law; (j) amending the Constitution without following the proper procedure; and (k) destroying the independence of the judiciary.

Arguments of the Respondents

• 1. The respondents, represented by the Solicitor General, argued that Section 14 does not add qualifications for Supreme Court Justices, does not remove Justices from office, does not create a special Supreme Court, and does not impair the rule-making power of the Supreme Court. They contended that the provision is constitutional and necessary for the proper administration of justice in treason cases.

Issues

• 1. The main issue is whether Section 14 of the People's Court Act is constitutional.

Ruling

• 1. The Supreme Court ruled that Section 14 is unconstitutional. The Court held that the provision violates the constitutional requirements for the appointment and qualifications of Supreme Court Justices. It also undermines the independence of the judiciary by allowing the President to designate lower court judges to sit in the Supreme Court, bypassing the constitutional process of appointment and confirmation by the Commission on Appointments.

Doctrines

• 1. Separation of Powers: The Court emphasized the importance of maintaining the independence of the judiciary from legislative and executive interference.
• 2. Constitutional Supremacy: Any law that conflicts with the Constitution is void.
• 3. Judicial Independence: The judiciary must be free from external influences to ensure impartial administration of justice.

Precedents Cited

• 1. In re Guarina (24 Phil. 37): Cited to emphasize that no act of the legislature repugnant to the Constitution can become law.
• 2. Marbury v. Madison (1 Cranch 175): Cited to support the principle of judicial review and the supremacy of the Constitution over legislative acts.

Statutory and Constitutional Provisions

• 1. Article VIII, Sections 4, 5, 6, 9, and 13 of the Philippine Constitution: These sections outline the composition, appointment, qualifications, and tenure of Supreme Court Justices, as well as the rule-making power of the Supreme Court.
• 2. Section 14 of Commonwealth Act No. 682 (People's Court Act): The provision challenged in this case.