231671, July 25, 2017 resolve the instant cases for the guidance of
the Congress, State actors, and all Filipinos.
Alexander A. Padilla, et al. vs. Congress
of the Philippines Consequently, the Congress convened in joint
session and approved by virtue of a majority
G.R. No. 231694
vote the extension of the proclamation and
Former Senator Wigberto E. Tanada, et suspension in Mindanao until December 31,
al. vs. Congress of the Philippines 2017.
(2) The usual procedure for having a Therefore, the Court has no authority to
joint session is for both Houses to compel the Senate and the House to convene
first adopt a Concurrent Resolution in joint session absent a clear ministerial duty
to hold a joint session. on its part to do so under the Constitution and
in complete disregard of the separate actions
With neither Senate nor the House adopting a
already undertaken by both Houses on
concurrent resolution, no joint session by the
Proclamation No. 216, including their
two Houses of the Congress can be had in the
respective decisions to no longer hold a joint
present cases. The Court is bound to respect
session, considering their respective
the rules of the Congress as a co-equal and
resolutions not to revoke said Proclamation.
independent branch of government.
Moreover, both Houses already separately
expressed support for P.RRD’s proclamation,
so revocation was not even a possibility and
the provision on revocation under the
Constitution requiring Congress to vote jointly
in a joint session never came into operation.