Case Digest: Santiago vs Guingona

ISSUE:  Whether or not there was an actual violation of the Constitution in the selection of respondent as Senate minority leader 

FACTS:  During the election of officers in the Senate, Sen. Marcelo Fernan and Sen. Tatad were both nominated to the position of Senate President. By a vote of 20 to 2, Sen. Fernan was declared the duly elected Senate President. Thereafter, Sen. Tatad manifested that, with the agreement of Sen. Santiago, allegedly the only other member of the minority, he was assuming position of minority leader. He explained that those who had voted for Sen. Fernan comprised the “majority,” while only those who had voted for him, the losing nominee, belonged to the “minority.” However, senators belonging to the Lakas-NUCD-UMDP Party – number 7 and, thus, also a minority – had chosen Sen. Guingona as the minority leader. Thus, Petitioners filed this case for quo warranto.

RATIO DECIDENDI:  The term “majority” has been judicially defined a number of times. When referring to a certain number out of a total or aggregate, it simply “means the number greater than half or more than half of any total.” The plain and unambiguous words of the subject constitutional clause simply mean that the Senate President must obtain the votes of more than one half of all the senators. Not by any construal does it thereby delineate who comprise the “majority,” much less the “minority,” in the said body. And there is no showing that the framers of our Constitution had in mind other than the usual meanings of these terms.In effect, while the Constitution mandates that the President of the Senate must be elected by a number constituting more than one half of all the members thereof, it does not provide that the members who will not vote for him shall ipso facto constitute the “minority,” who could thereby elect the minority leader. Verily, no law or regulation states that the defeated candidate shall automatically become the minority leader.