Case Digest: [Separate Opinion] Integrated Bar of the Philippines v. Hon. Ronaldo Zamora, G.R. No. 141254, August 15, 2000

Political Law Review | Interpretation/Construction of the Constitution

Puno, CJ:

  • The Integrated Bar of the Philippines (IBP) sought to halt joint patrols conducted by the Philippine National Police and the Marines in Metro Manila.

  • Petitioners claimed these joint operations violated the principle of civilian supremacy over the military.


Whether members’ floor statements at the Constitutional Convention should be given weight particularly when courts seek to interpret constitutional provisions.  

  • Convention speeches are informative but limited.

  • An individual delegate’s opinion expressed during the Constitutional Convention is valuable but not necessarily reflective of the people’s intent.

  • Unlike statutes, where courts seek legislative intent from legislative debates , the interpretation of the Constitution aims to ascertain the intent of the people, through the deliberations of their elected representatives.

  • The Constitution derives its force from ratification, not drafting. The Constitution’s authority comes from the people who ratified it, not from the Convention itself.

  • Thus, courts aim to uncover what the people intended, not merely what individual framers thought.



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