Faderanga v. Commission on Elections
REITERATIONFacts
The Antecedents: Petitioners were candidates for various elective positions in Banton, Romblon. A petition was filed with the Commission on Elections (COMELEC) seeking their disqualification for allegedly changing party affiliation within six months before the election. Despite the pending petition, petitioners won and were proclaimed on January 31, 1980. A telegram from COMELEC to suspend the proclamation was received late on the same day. The disqualification petition was denied for lack of evidence on February 28, 1980. Petitioners were proclaimed anew on March 3, 1980, and took their oaths of office. Procedural History: Private respondents filed a motion for reconsideration on March 19, 1980. Petitioners opposed, arguing that reopening the proceedings would annul the finality of the proclamation, contrary to the Election Code. The motion was heard and submitted on September 29, 1980. On December 29, 1980, COMELEC reversed its earlier resolution and granted the disqualification, effectively nullifying the proclamation. The Petition: Petitioners filed a certiorari and mandamus petition with the Supreme Court on January 19, 1981, assailing the December 29, 1980 resolution of COMELEC, alleging grave abuse of discretion. A temporary restraining order was issued on January 20, 1981.
Issue(s)
Whether the Commission on Elections committed grave abuse of discretion in reversing its resolution and disqualifying the petitioners after they had been proclaimed and assumed office, and whether a pre-proclamation controversy can be prolonged and resolved after the proclamation of winning candidates.
Ruling
The petition is granted. The order of December 29, 1980, is nullified and set aside for amounting to a grave abuse of discretion. The right of petitioners as duly elected officials to continue in office is affirmed, subject to private respondents instituting an election protest or a quo warranto proceeding within fifteen (15) days after receipt of the decision. The temporary restraining order is made permanent and the decision is immediately executory.
Ratio Decidendi
On the issue of grave abuse of discretion and the prolongation of pre-proclamation controversies: The Supreme Court reiterated its consistent adherence to the principle that once candidates have been proclaimed and have assumed office, a pre-proclamation controversy regarding disqualification should no longer prosper. The Court cited previous rulings such as Venezuela v. Commission on Elections, Villegas v. Commission on Elections, and Potencion v. Commission on Elections, which established that the proper remedies after proclamation are an election protest or a quo warranto petition. The Court emphasized that allowing such controversies to be prolonged after proclamation would be contrary to the established legal framework and the principle of finality in election results. The resolution of COMELEC on December 29, 1980, which reversed its earlier denial of disqualification and effectively nullified the proclamation of the petitioners, was deemed a grave abuse of discretion. This was particularly so because the petitioners had already been proclaimed twice, taken their oaths of office, and were continuing to hold their positions. The Court noted that even COMELEC itself had initially denied the disqualification for lack of evidence, affirming the petitioners' right to be proclaimed. To upset the existing conditions would be detrimental to stability in Banton, Romblon. The Court stressed that in resolving pre-proclamation controversies after a considerable period, COMELEC should accord respect to a proclamation made after due deliberation, without prejudice to a protest or quo warranto action. The Court's pronouncements in Aguinaldo v. Commission on Elections further supported this stance, stating that petitions for disqualification filed after the election and proclamation should be dismissed without prejudice to being passed upon in a proper election protest or quo warranto proceeding, unless the issue was seasonably invoked and acted upon by COMELEC prior to the election and elevated to the Supreme Court before the election. The Court also referenced Arcenas v. Commission on Elections, where it sustained COMELEC's dismissal of a disqualification action, highlighting that such actions should not be objectionable when the victor has already been proclaimed. Therefore, the assailed resolution of COMELEC was nullified as it disregarded established jurisprudence and the finality of proclamation, constituting a grave abuse of discretion.
Main Doctrine
A pre-proclamation controversy, particularly concerning a candidate's disqualification based on party affiliation change, must be resolved before proclamation. Once candidates are proclaimed and have assumed office, the proper remedies are an election protest or a quo warranto proceeding, not a petition for certiorari and mandamus to nullify the proclamation, absent grave abuse of discretion by the COMELEC.