Teves v. Commission on Elections
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the right of qualified voters residing in Dumaguete City to participate in the election of provincial officials for Negros Oriental. The Commission on Elections (COMELEC) issued an opinion stating that these voters are not eligible to vote for the provincial governor and members of the provincial board. This decision stems from the interpretation of Dumaguete City's charter, which, unlike those of some other cities, does not explicitly grant or deny this voting right. 2. Procedural History: The case originated when the City Attorney of Dumaguete City requested an opinion from the Commission on Elections regarding the voting rights of the city's residents in provincial elections. Following COMELEC's adverse opinion on August 24, 1951, a group of registered voters from Dumaguete City filed a special action for mandamus with the Supreme Court. They alleged that COMELEC refused to provide necessary election paraphernalia for them to vote in the upcoming November 13, 1951, elections for provincial officials. 3. The Petition: Petitioners, qualified and registered voters of Dumaguete City, seek a writ of mandamus to compel the Commission on Elections to provide them with the necessary election paraphernalia. Their petition is based on the argument that since Dumaguete City's charter is silent on the matter, and its residents are inhabitants of Negros Oriental province, they retain the right to vote for provincial officials. They contend that the silence in the charter should not be interpreted as a withdrawal of this right, especially in the absence of an express prohibition, and that the city's separation from the province for governmental purposes does not extinguish their right to vote for provincial leadership.
Issue(s)
Whether the qualified voters of Dumaguete City are entitled to vote for the provincial governor and members of the provincial board of Negros Oriental. Whether the Commission on Elections has the power to decide on the right to vote, and if so, whether its refusal to provide election paraphernalia constitutes a grave abuse of discretion.
Ruling
The petition is dismissed. The Supreme Court ruled that the voters of Dumaguete City have no right to participate in the election of the provincial officials of Negros Oriental, and consequently, the Commission on Elections has no corresponding duty that can be enforced by mandamus.
Ratio Decidendi
On the right of Dumaguete City voters to vote for provincial officials: The Court held that the creation of Dumaguete City made it a political entity separate from and independent of the Province of Negros Oriental. The purpose of an election is to allow the electorate to choose the men who will run their government. Allowing city voters to participate in the election of provincial officials, over whom the province has ceased to have governmental jurisdiction and authority, serves no useful end. The Court pointed to Section 89 of Republic Act No. 327, the charter of Dumaguete City, which states that the city shall continue as part of the first representative district of Negros Oriental. This provision was interpreted not as an extension of the right to vote for provincial officials, but as an express exception to the general effect of separation, reinforcing the rule that city inhabitants may not vote for provincial officials but may vote for their representative in Congress. The Court also noted a prior ruling by the COMELEC on September 2, 1947, regarding Davao City, where it was held that silent city charters imply the exclusion of voting rights for provincial officials, suggesting that Congress, by omitting such a provision in Dumaguete's charter, was confirming this interpretation. On the power of the Commission on Elections and the propriety of mandamus: Since the Court concluded that the voters of Dumaguete City have no right to vote for provincial officials, it followed that the COMELEC had no corresponding duty to provide election paraphernalia for such purpose. Therefore, mandamus, which is a writ compelling a public officer to perform a ministerial duty, was not the proper remedy. The COMELEC's opinion and subsequent refusal were deemed not to constitute a grave abuse of discretion because they were based on a legal interpretation of the city's charter and its relationship with the province.
Main Doctrine
The creation of a chartered city, unless otherwise expressly provided, separates it from the province for purposes of provincial elections, and its residents are not entitled to vote for provincial officials.