Osmea vs Pendatun

GR L-17144
October 28, 1960
Facts: Petitioner, Congressman Sergio Osmea, Jr. gave a privileged speech wherein
he had stated that under the President, free government services are paid for at
premium prices, including pardons. Congressman Salapida Pendatun and 14 other
congressmen were tasked as members of a special committee. House Resolution
59, which was made by Pendatun and the others required him to substantiate his
charges against the President with the admonition that if he failed to do so, he must
show cause why the House should not punish him. After giving time for petitioner to
defend himself HR 175 was filed and passed finding petitioner guilty of serious
disorderly behaviour, and suspended for 15 months. Petitioner Contends that his
parliamentary privilege does not allow that he be suspended, especially with the
advent of Section 15, Article VI that indicates "for any speech or debate" in
Congress, the Senators or Members of the House of Representative "shall not be
questioned in any other place."
Issue: WON Petitioner is liable for his speech.
Held: Yes. The parliamentary privilege 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 of the Congressional Hall. But this does
not protect him from responsibility before the legislative body itself whenever his
words and conduct are considered by the latter disorderly or unbecoming a member
thereof. The case in point, it becomes a political question on which the courts would
not have any jurisdiction over. The House can determine what it finds as disorderly
behaviour and that there are no provisions that would allow the court to interfere
with the findings of the Legislative as it would infringe on the doctrine of separation
of powers. Regarding the process, the court finds no discrepancy in the process
taken by Congressman Pendatun and the Special Committee in sanctioning the
suspension of petitioner.