### Facts:
1. **Background on Sandiganbayan:**
– On June 11, 1978, President Ferdinand E. Marcos created the Sandiganbayan via Presidential Decree No. 1486.
– Later, Presidential Decree No. 1606, issued on December 10, 1978, elevated the rank of its members to Justices.
– Republic Act No. 7975 (1995) and Republic Act No. 10660 (2015) later expanded the Sandiganbayan to 20 Associate Justices operating in multiple divisions.
2. **Call for Applications:**
– On July 20, 2015, the Judicial and Bar Council (JBC) published a call for applications for the six newly created positions at the Sandiganbayan.
3. **Shortlist Submission:**
– On October 26, 2015, the JBC submitted six distinct shortlists for the six vacancies at Sandiganbayan to President Benigno Simeon C. Aquino III.
4. **Appointments by President Aquino:**
– On January 20, 2015, President Aquino appointed six new Sandiganbayan Associate Justices.
– Two of the appointed, Musngi and Econg, were originally shortlisted for the 21st Associate Justice position but were appointed to the 16th and 18th positions respectively.
5. **Petition Details:**
– Judges Aguinaldo, Alhambra, Cruz, Pozon, and Timbang were among the nominees for the 16th Associate Justice position, asserting direct injury from not being appointed.
– The Integrated Bar of the Philippines (IBP) joined the petition via a taxpayer’s suit, claiming the appointments involved matters of public interest.
6. **Legal Filings:**
– Petition for Quo Warranto under Rule 66, Certiorari and Prohibition under Rule 65.
– Respondents argued that President Aquino holds immunity from suit and contested the procedural basis for the petitions.
### Issues:
1. **Scope of Presidential Power in Judicial Appointments:**
– Does the President have the authority to appoint from any nominee listed by the JBC for the overall vacancies, or must appointments be strictly within the specific shortlists for each vacancy?
2. **Jurisdictional and Procedural Challenges:**
– Are the petitioners (Judges and IBP) proper parties with legal standing to challenge the appointments?
– Was President Aquino immune from suit at the time of the petition filing?
– Have the petitioners violated the hierarchy of courts by elevating the issue directly to the Supreme Court?
3. **Constitutional Interpretation of Article VIII, Section 9:**
– Does the clustering of nominees by the JBC restrict and infringe upon the President’s discretion in appointments?
### Court’s Decision:
1. **Legal Standing and Procedural Issues:**
– Certiorari and prohibition were admitted owing to transcendental importance, despite questions on procedural aspects.
– Petition for Quo Warranto was denied because petitioners did not demonstrate an unequivocal right to the positions.
– President Aquino was dropped as a respondent due to presidential immunity; however, actions were reviewed in light of Secretary Ochoa’s involvement.
2. **Presidential Appointment Power:**
– The Court emphasized that the JBC’s role was to recommend, while the President’s discretion in appointments remained paramount.
– The ruling noted that the Constitution mandates the JBC to submit “at least three nominees for every vacancy,” thus the President could select from the entirety of the lists provided by the JBC.
– The clustering of nominees restricts the President’s constitutional prerogative of appointing Justices.
3. **Clustering Invalidation:**
– The JBC’s clustering was found unconstitutional as it unduly limited presidential discretion and caused undue restrictions on both the appointees and the appointing process.
4. **Appointments Validity:**
– Appointment of Justices Musngi and Econg, and the other four Sandiganbayan justices, were validated and declared in line with the constitutional provisions.
### Doctrine:
– The President’s power to appoint judges is confined to the list of nominees prepared by the JBC but not restricted to specific vacancies based on the clustering of said nominees.
– Clustering of nominees by the JBC for simultaneous vacancies in collegial courts is unconstitutional when it unduly restricts the appointment powers of the President.
### Class Notes:
1. **Presidential Appointment Power:**
– President can choose from all nominees recommended for multiple vacancies by the JBC.
2. **Judicial and Bar Council Role:**
– Recommends (not restricts) nominees; cannot cluster to influence appointment process.
3. **Article VIII, Section 9:**
– Allows flexibility for presidential appointment provided the JBC’s list includes at least three nominees per vacancy.
4. **Judicial Review Invocation:**
– Expanded power allows review of erroneous executive actions if claims of grave abuse of discretion exist.
### Historical Background:
– The Sandiganbayan was established to address graft and corruption, performing as a special court with evolving structures and functions.
– The JBC aims to depoliticize the judicial appointment process, acting as a recommender to balance executive appointment powers.
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