The Coup: Constitutional or Not? A Question with Consequences for the Future
Originally published in Spanish by AJS's Honduran sister organization, la Asociación para una Sociedad más Justa, at:

http://asjhonduras.com/cms/index.php?option=com_content&view=article&id=86:golpe-de-estado-iconstitucional-o-no-una-pregunta-con-consecuencias-futuras&catid=31:golpe-de-estado&Itemid=88

After the monumental events of June 28, Hondurans ought to reflect whether civil society’s fight for strong institutions, such as the new Supreme Court with 15 justices dedicated to the application of laws and the functioning of the system, has been worth it.

In many places, especially in Tegucigalpa, there are white billboards, many with the images of farmers, thanking Roberto Micheletti, the Supreme Court, and the Armed Forces for “defending our Constitution.”
But on the other side there is a large section of the population the denounces the actions of June 28 as a coup d’état.

But let's review the facts and the arguments that have been presented:

After the arrest and expatriation of President Zelaya, the National Congress met in an emergency session and voted to accept the supposed letter of resignation signed by Zelaya, and then replace him in a “constitutional succession.”

The Supreme Court released to the general population the case file for Manuel Zelaya.

Many people, from religious leaders to members of civil society, have tried to explain why Zelaya’s expatriation was necessary. But what does the constitution say?

The following arguments have been used to justify the coup:

1.) What happened was a constitutional succession, because the prosecutor presented charges against Zelaya, and the Supreme Court ordered his arrest.
On June 25, 2009, the prosecutor’s office presented the charges against President Zelaya, accusing him of the following crimes: attempting to change the form of government, Treason, Abuse of Authority and Usurpation of Functions, as well as attempting to hold a survey to justify the creation of a National Constitutional Assembly.

On June 26, the Supreme Court, responding to the charges filed against Zelaya, issued an arrest warrant, directed at the head of the Armed Forces to execute Zelaya’s arrest. It was signed by Justice Tomas Arita Valle (from the Labor Court). Another arrest warrant was emitted to Coronel Rene Antonio Hepburn to raid Zelaya’s house.

On June 29, the Supreme Court expressed in its document of considerations, “Considering that it is public and common knowledge that citizen José Manuel Zelaya Rosales has ceased to hold office as constitutional President of the Republic, the reasons for which were presented in these charges filed in the Supreme Court of Justice, so that the established procedure of the penal code that regulates the process for prosecuting the State’s highest officials… Resolves: To remit these charges to the Penal Court of Letters of the Department of Francisco Morazán to continue with the ordinary process established in the Penal Code.”

2.) What happened was a Constitutional Succession because the Congress approved it.
The Congress voted in Decree 141-2009 to remove Zelaya from office as President. This decree was approved right after Zelaya was sent to Costa Rica. In this decree, Congress argued that since no one is above the law and President Zelaya’s conduct had been erratic, Congress would disapprove of his conduct, remove him from office and replace him with President of Congress Roberto Micheletti.

This Congressional decree backs the arrest warrant issued by the Supreme Court on June 26.

3.) What happened was a constitutional succession, because Zelaya violated Article 239 of the Honduran Constitution.
Manuel Zelaya was proposing a National Constitutional Assembly, which, it was expected, would result in a new constitution. Although most articles can be reformed, this is not the case with the so-called “articles set in stone,” which are those that refer to the form of government, national territorial boundaries, the presidential term limit, and the regular election of new presidents.

Since there are only four articles that cannot be ammended except by Constitutional Assembly, it can be deduced that Zelaya had the intention of changing at least one these. If this were the case, the succession was fair because anyone who suggests or supports reforming any of these articles immediately looses public office, according to article 239.

This article says: “Any citizen who has served in the Executive Power cannot be president or vice-president of the Republic. Whoever breaks this disposition or proposes its reform, as well as anyone who supports it directly or indirectly, will immediately loose his position and be unable to perform any public function for a period of 10 years.”

The problem with these three arguments:

1) The Supreme Court: There are four problems with this argument.

1. According to the Constitution, the Supreme Court has the legal authority to judge high-ranking officials but must follow the Penal Code by holding a trial with four members of the Court. This did not happen, however, as Zelaya was expatriated. 

According to Article 312 numeral 2) of the Constitution: “The Supreme Court will have the following attributes: Be familiar with cases opened against high-ranking government officials and deputies.” But the constitution does not provide instructions for carrying out the trial. For that, the Penal Code  must be consulted. 

The Penal Code has four articles about how to carry out a trial against a state executive. Articles 414-417 give the following provisions for a trial:
•    The Supreme Court is made familiar with the charges, which were presented by the Attorney General.
•    The Supreme Court will designate a Justice to become familiar with the case. If there is a trial, three Court Justices will preside. 

It seems that the Supreme Court began this process but only got as far as designating a Justice to read the case. It never reached trial, because the army took Zelaya to Costa Rica instead of presenting him to the judge.

The Supreme Court’s decision included various arguments and references to the Law but no legal justification for removing the President from office. In particular, a section on page 80 of Court-issued documents points out, “it is public and common knowledge that citizen José Manuel Zelaya Rosales has ceased to hold office as constitutional President of the Republic” without explaining either how this knowledge existed or how Zelaya had ceased to hold office.

2. It is interesting to note that the document issued on June 29, 2009 contains the signatures of only seven of fifteen Supreme Court Justices, eight short of the full session that the case required. Secondly, in this and other court-issued documents, the signature of Germán García appears as an “Integrated Justice” instead of Supreme Court Justice Carlos Cálix’s. If the decision to arrest Zelaya was unanimous, why was it signed by an acting Supreme Court Justice and what powers does he have?

3. The document was issued on June 29, one day after Zelaya had been sent to Costa Rica and three days after the arrest warrant had been issued.

4. Supreme Court Judge Tomás Arita issued an arrest warrant to the Armed Forces, whereas the authority to carry out arrests corresponds only to the National Police. Did Tomás Arita not know this?

2) Congress: There are three problems with this argument.

1. Congress agues that President Zelaya was violating the law (specifically assault on the form of government, treason, abuse of authority and usurpation of functions against public administration and the State of Honduras); however in none of these cases does Congress have the power to remove a president from office. Only the Supreme Court can do this as described above.

Congress, in its decree to remove the President from office, cited various articles of the Constitution with the intention of justifying its actions: 1, 2, 3, 4, 5, 40 number 4, 205 number 20, 218 number 3, 242, 321, 322 and 323; however none of these articles gives Congress the power to remove a president from office. In fact, according to law professor Olvin Rodríguez of the Autonomous National University of Honduras (UNAH), “Congress removed the President from office without having the express or tacit, explicit or implicit constitutional powers to do so.” Article 205, which defines Congress’s powers, makes no provision for penalizing the President. Congress has not been able legally to justify its action; nevertheless the Supreme Court has not declared it illegal.

2. Because Congress presented the decree after the army had already removed Zelaya from the country, it seems to have been an effort to justify the action.

3. Twenty-one congress people, among them Elvia Valle, affirm that they were not called to the vote on the decree, and 26 voted against it. This indicates that the vote was neither transparent nor unanimous.

3) Article 239 of the Constitution
Days after the coup d’état, many of its supporters, such as Roberto Micheletti, cited Article 239 to justify it; but there are problems with this argument, too.

1. Neither Congress’s decree nor the Supreme Court documents mention this article.

2. There are no regulations for implementing Article 239; it is considered to be self-executing. That means that the moment someone proposes to reform the Article, he or she automatically forfeits public office; however, according  to international law expert Doug Cassel of Notre Dame’s Law Faculty, this concept raises even more questions:

“…[T]o treat this provision as “self-executing” is problematic. For example, if President Zelaya violated Article 239, when did he cease to be president? Months ago, when he openly began to advocate a constitutional reform to allow his re-election?[56] And who is to say? Do the courts decide? Does the Congress? What if they disagree? What if the president disputes their accusation? What is the evidentiary standard? How and when does Honduras know that it no longer has a lawfully elected president? Plainly Article 239 is unworkable without some procedure to implement it.

Rigoberto Cuellar, a Honduran Constitutional specialist, explains that because Article 239 is so open, Congress has the right to declare that Zelaya was violating it; and, even though many (foreigners) disapprove of the Article, it continues to exist, and Congress must interpret it. “There are two ways to remove a president from office, although the Constitution does not speak only of presidents but also of any public official. One is following a strictly judicial course and another is following a strictly political course,” says Cuellar. “Our country, like most countries, conceives of both courses. Where our Constitution falls a little short is that it does not develop with exactness the procedure that should be followed for a political trial... that although the Constitution does not say it, in a political process, the entity responsible for issuing the decree (regarding Article 239) is Congress.”

On the contrary, according Article 304 of the same Constitution, juristictional organisms are responsible for deciding cases and executing rulings.

But even if Dr. Cuellar were right, although Congress creates and interprets laws according to Article 205 of the Constitution, the Supreme Court applies them according to Article 304. If Congress had voted after a trial, it would have had the legal backing for removing the president from office; but Congress voted without due legal process.

3. The historical application exposes further problems with Article 239. For example, Roberto Micheletti lead a campaign to reform the constitution in 1985, just three years after he had helped draft it, so that then-President Suazo Córdoba could remain in office. Micheletti thereby directly and publicly committed the same crime of which he accuses Zelaya.

According to Cuellar, proposing a constituent assembly constitutes an attack on the Constitution since, according to him, there is no other reason for writing a new constitution but to change the inalterable Articles; but then, if we base ourselves on the letter of the law, Micheletti should have been removed from office in 1985, and Pepe Lobo should have been suspended from all public office for ten years after voicing support for a constituent assembly in May of this year. However, in these cases, there was no “self-execution” of the law.

“In his eagerness to win votes (Pepe Lobo) said that he would favor a constituent assembly,” said Cuellar. “This, according to the Constitution, is a crime.”

This interpretation begs further questions. If merely proposing a constituent assembly violates Article 239, why did Congress not vote the moment Zelaya proposed a constituent assembly? Why did the Prosecutor’s Office not launch an investigation before the end of June? Is it possible to form a constituent assembly without changing the inalterable articles?

4. Interpreting Article 239 as self-executing violates other articles of the Constitution. If Article 239 is self-executing, it would seem to violate the articles that guarantee the right to freedom (61 and 69), the right to defend ones self (82), the principle of innocence (89) and the right to due legal process (92 and 94).

Upon deciding not to proceed with a trial, the Supreme Court and Armed Forces acted as if they did not have the proof necessary for convicting President Zelaya, or they did not believe that the justice system works.

If Article 239 is self-executing, it violates every citizen’s right to be assumed innocent until proven guilty.

In any case, Zelaya did not respect the law either, because he continued preparations for the referendum against the orders of a judge of Administrative Dispute.

So José Manuel Zelaya does not believe that the justice system works, either, or he didn’t want it to work.

Two Mistakes
If the coup d’etat stands, this essentially affirms that Congress had the power to remove a president from office, which sets precedents for the future. But it is clear that the powers of the State made two very important mistakes that have left the Honduran people with very dangerous precedents.

1. Article 102 of the Constitution was violated, which says “No Honduran can be expatriated or handed over by the authorities of a foreign State.” This article could not be clearer.
As law professor at the Autonomous National University of Honduras Ramón Enrique Barrios says, “Regarding the fact that they invoked the figure of the state of necessity to remove him from his country, the order issued by the judge was to arrest him, not to expatriate him from his country (which violates the Constitution).”

The Armed Forces says that they made this decision in order to avoid a violent uprising upon arresting President Zelaya. The Armed Forces’ legal advisor admits that Zelaya’s expatriation was illegal. Where is the report on these events? Why has the Constitutional Court not requested an explanation from the Armed Forces?

“We know that there is a crime there,” said  Coronel Herbeth Bayardo Inestroza on news site Elfaro.net. “The moment we removed him from the country, in the way in which he was removed, there is a crime.”
Dr. Cuellar says that this act was, in his opinion, the only illegal act. According to Cuellar, the Court can argue that the military acted because of the state of necessity, but a judge would have to make this determination.

“The military supposedly unilaterally made the decision to expel him from the country, this is something else,” said Dr. Cuellar. “And there, the military’s responsibility for this act will have to be determined. They should be tried.”

2. Zelaya was not given any opportunity to defend himself before the Supreme Court of Justice. Essentially, the high officials were those who decided that Zelaya was guilty without previously having followed due process. Articles 92 and 94 guarantee a fair trial for each person accused of a crime. The coup and documentation presented after the coup to justify it is not transparent, just as the way in which the popular survey was convened was not transparent and therefore smacked of corruption.

In addition, one when Congress read Zelaya’s resignation letter, which is suspected to be false, it seemed that it was being used to hide the fact that due process had not been followed and to cover their illegal actions because they never mentioned it in the decree or in the documentation published after June 28. This also smells of corruption, and has provoked further distrust of the justice system.

Dangerous Precedents
The Constitution was written to provide the government with clear laws to be followed in the different situations in which the country may find itself. It was supposedly written rationally and carefully. Therefore it is very important that when a crisis arises, high officials act not according to external influences or their own interests but rather according to the letter of the law, always seeking the well-being of Honduras and its people.

Throwing the Constitution out the window means that there no are no longer rational laws for delimiting a government’s actions. Citizens should fear that high officials think they can manipulate the law and deceive the people.

We do have laws, but the problem is the functionaries who apply them. They provoke distrust in our justice system.

Honduras is now known at home and abroad as corrupt (Honduras is in the first third of the world’s most corrupt countries according to Transparency International) and will have to fight even harder to restore its reputation. A matter as important as the destitution of a president should be carried out with transparency and legal backing. High officials should have been able to prove to the world that the law rules in Honduras, but instead they showed the world that even the country’s high officials do not believe that the system works. Now, according to Cuellar, no side can say that it really defends the Constitution.
“Both groups, or let us say the representatives of both groups, President Manuel Zelaya as well as President Micheletti, the people behind Mel Zelaya and the people behind Micheletti, have lost their legitimacy to be able to maintain the positions that they are maintaining,” said Cuellar. “Neither of the two can speak of defending the constitutional order or respecting law or democracy. And we Hondurans know this.”

If those responsible for Zelaya’s expatriation are not investigated, the Armed Forces’ violation of the Constitution of the Republic will be justified, and the Armed Forces would then be above the law. This precedent is a set-back from the 80s, and it is what the world wants to avoid; but President Zelaya should also be tried for disregarding a judicial order when he insisted on carrying out a popular survey in violation of a court order to desist.

There is also the dangerous precedent that government branches can commit the same actions in the future; let us imagine, for example, that a president promotes very good changes legitimately oriented a helping the country’s poor, and officials of Congress and the Supreme Court decide that they do not like what he or she is doing, then they will be able to expatriate the president without legal justification. No one wants this to happen as a result of the current crisis. What is done now will definitely have implications for the future.
If those responsible believe that their actions were necessary to avoid violence, then they should turn themselves over to show that they acted in good faith. They should not hide their acts and pretend that what happened was legal. As Hondurans, we deserve to know the truth.

Therefore, Zelaya should return to Honduras to submit to a transparent, legal trial and be sentenced if he committed a crime. The same should happen with those who orchestrated the coup. It is the only way to respect the Constitution that supposedly everyone wants to defend.