G.R. No.

L-53869 March 25, 1982

RAUL A. VILLEGAS, petitioner, vs. ASSEMBLYMAN VALENTINO L. LEGASPI, respondent
FACTS:
In September 1979, Raul Villegas filed a civil case against spouses Vera Cruz et al before the Court of First
Instance (CFI) Cebu. The Vera Cruz spouses filed their answer to the complaint and they were represented
by Valentino Legaspi, then a member of the Batasang Pambansa. Villegas then challenged the
representation made by Legaspi as counsel for the spouses on the ground that it is unconstitutional; as
pointed out by Villegas “no member of the Batasang Pambansa shall appear as counsel before any
court without appellate jurisdiction”. The presiding judge however overruled Villegas’ challenged and
proceeded with the trial. The judge said that CFIs have appellate jurisdiction.
VILLEGAS
“challenged” the appearance of Assemblyman Legaspi as counsel of record on the ground that he is barred
under the Constitution from appearing before Courts of First Instance, which are essentially trial Courts or
Courts of First Instance, which are essentially trial Courts or Courts of First Instance, which are essentially
trial Courts or Courts of original jurisdiction.

ISSUE HELD RATIO

Whether or not No. Members of CFI’s have dual personalities. They can be courts of general
the Congress are prohibited original jurisdiction (courts of origin) or appellate courts
said member, to appear as counsel depending on the case that they took cognizance of. In the
Valentino berfore CFI’s acting in cases at bar, CFI Cebu and CFI Rizal acted as a courts of
Legaspi, of the their original jurisdiction. general original jurisdiction. Both cases were not elevated to
Batasang the said CFIs from any lower courts. Thus, the CFIs in the
Pambansa may case at bar are “courts without appellate jurisdiction”.
appear as
counsel before Appearance of the legislator is now barred before all courts
the said CFI. of justice, regardless of rank, composition, or jurisdiction. The
disqualification also applies to the revived Electoral Tribunal
and to all administrative bodies, like the Securities and
Exchange Commission and the National Labor Relations
Commission. Courts martial and military tribunals, being
administrative agencies, are included.
Section 14, Article VI No Senator or member of the House of Representatives may personally appear as
counsel before any court of justice or before the Electoral Tribunals, or quasi-judicial and other
administrative bodies. Neither shall he, directly or indirectly, be interested financially in any contract with,
or in any franchise or special privilege granted by the Government, or any subdivision, agency, or
instrumentality thereof, including any government-owned or controlled corporation, or its subsidiary,
during his term of office. He shall not intervene in any matter before any office of the Government for his
pecuniary benefit or where he may be called upon to act on account of his office.