Case Digest: Pobre vs. Defensor Santiago

ISSUE:  Whether or not there is a ground for Sen. Defensor-Santiago to be disbarred or subjected to disciplinary action by the Court for her questioned speech 

FACTS:  In one of her privilege speeches before the Senate, Sen. Miriam Defensor-Santiago delivered the following remarks:  x x x I am not angry. I am irate. I am foaming in the mouth. I am homicidal. I am suicidal. I am humiliated, debased, degraded. And I am not only that, I feel like throwing up to be living my middle years in a country of this nature. I am nauseated. I spit on the face of Chief Justice Artemio Panganiban and his cohorts in the Supreme Court, I am no longer interested in the position [of Chief Justice] if I was to be surrounded by idiots. I would rather be in a different environment than in a Supreme Court of idiots. x x x Her speech came as a response to the decision of the Judicial and Bar Council (JBC) declaring that only sitting members of the Supreme Court can be nominated for the impending vacancy of the CJ post. Consequently, nominees who were not incumbent members of the Court, including Sen. Defensor-Santiago, were automatically disqualified.  Private complainant Antero J. Pobre filed the instant petition before the Court, contending that the lady senator's utterances amounted to a total disrespect towards then CJ Panganiban and a direct contempt of Court. Accordingly, he wanted disbarment proceedings or other disciplinary actions to be taken against Sen. Defensor-Santiago.  
   
RATIO DECIDENDI:  o, the Court sided with Sen. Defensor-Santiago's defense that she should be afforded parliamentary immunity from suit pursuant to Section 11, Art. VI of the 1987 Constitution, which section states in part that "no [Senator] x x x shall be questioned nor be held liable in any other place for any speech or debate in the Congress or in any committee thereof." Although there was no express admission on the part of the lady senator that she did indeed say those words, there was no categorical denial either, which the Court ultimately regarded as an implied admission.  Despite the dismissal of the letter-complaint, the Court heavily chastised the lady senator for indulging in "insulting rhetoric and offensive personalities." In fact, her excuse that her questioned speech was a prelude to crafting remedial legislation on the JBC struck the Court as being a mere afterthought in light of the controversy her utterances had managed to stir.  Still, the Court held  that parliamentary immunity is essential because without it, the parliament or its equivalent would "degenerate into a polite and ineffective forum." However, it should be noted that "[l]egislators are immune from deterrents to the uninhibited discharge of of their legislative duties, not for their private indulgence, but for the public good."