Cua v. Commission on Elections
NEW DOCTRINEFacts
The Antecedents: The First Division of the Commission on Elections (COMELEC) rendered a 2-1 decision favoring petitioner Cua in SPC No. 87-454 and SPC No. 87-467. However, Cua's proclamation as winner was suspended due to the lack of a unanimous vote required by COMELEC Resolution No. 1669. Procedural History: Private respondent Puzon filed a motion for reconsideration/appeal with the COMELEC en banc. The COMELEC en banc, with three members voting to sustain the First Division's decision, two dissenting, and one abstaining, declared Cua's proclamation valid. Cua took his oath, but Puzon filed a motion to suspend or annul the proclamation. The COMELEC issued a restraining telegram enjoining Cua from assuming office. The Petition: Cua filed a petition with the Supreme Court to enjoin the COMELEC from acting on Puzon's motion and enforcing its restraining order.
Issue(s)
Whether the 2-1 decision of the COMELEC First Division was a valid decision of the COMELEC itself, despite COMELEC Resolution No. 1669 requiring a unanimous vote. Whether the decision of the COMELEC en banc, with three votes affirming the First Division's decision, constituted a valid majority vote. Whether the proclamation of Cua was valid.
Ruling
The Supreme Court granted the petition, lifted the COMELEC's restraining order, and enjoined the COMELEC from further proceeding with Puzon's motion. The Court held that the 2-1 decision of the First Division was valid under Article IX-A, Section 7 of the Constitution, and the 3-2 decision of the COMELEC en banc also constituted a valid majority. Cua's proclamation was therefore valid, entitling him to assume his seat.
Ratio Decidendi
On the validity of the First Division's decision: The Court held that the 2-1 decision of the First Division was a valid decision under Article IX-A, Section 7 of the Constitution, which states that each Commission shall decide by a majority vote of all its members. While COMELEC Resolution No. 1669 required a unanimous vote for a division's decision to be considered a decision of the Commission, this rule was superseded by the constitutional provision when a unanimous vote was not obtained. The case then became appealable to the COMELEC en banc. On the validity of the COMELEC en banc's decision: The Court found that the three members who voted to affirm the First Division's decision constituted a majority of the five members who deliberated and voted en banc. This 3-2 vote was therefore a valid decision of the Commission en banc under the same constitutional provision. The respondents' contention that no valid decision was reached because the First Division's vote was not unanimous was rejected. On the validity of Cua's proclamation: Based on the validity of both the First Division's decision (which was affirmed en banc) and the COMELEC en banc's decision, the Court concluded that Cua's proclamation was a valid act. Consequently, he was entitled to assume his seat in the House of Representatives. The Court expressed its expectation that these rulings would resolve the ongoing debates and allow the unrepresented people to have representation.
Main Doctrine
A 2-1 decision of a COMELEC Division, where a unanimous vote is required by its rules but not obtained, can be appealed to the COMELEC en banc, and the decision of the COMELEC en banc, based on a majority vote of its members, shall be the decision of the Commission. The constitutional mandate for a majority vote of all members applies to the COMELEC en banc.