Lazatin v. Commission on Elections
NEW DOCTRINEFacts
The Antecedents: Petitioner Carmelo F. Lazatin filed a petition assailing the jurisdiction of the Commission on Elections (COMELEC) to annul his proclamation as Congressman of the First District of Pampanga, after he had already taken his oath of office, assumed office, and discharged his duties. Procedural History: Respondents Francisco R. Buan, Jr., and Lorenzo G. Timbol alleged that the COMELEC Resolution had become final and executory before the Supreme Court issued a temporary restraining order. They also claimed the COMELEC hastily proclaimed petitioner Lazatin without resolving their protests against certain election returns. The COMELEC, in its separate comment, alleged that the proclamation was illegal and void because the board corrected contested returns without waiting for the final resolution of pending petitions. The Petition: Petitioner sought to annul the COMELEC's revocation of his proclamation, asserting that the House Electoral Tribunal, not the COMELEC, is the sole judge of all election contests, citing Section 17, Article VI of the 1987 Constitution.
Issue(s)
Whether the COMELEC has jurisdiction to annul the proclamation of a Congressman after he has taken his oath of office and assumed his duties. Whether the Supreme Court should take cognizance of the electoral protest against the petitioner, considering the alleged invalidity of the proclamation and the pendency of rival candidates' protests.
Ruling
The Supreme Court set aside the revocation by the COMELEC of petitioner's proclamation. The Court held that for it to take cognizance of the electoral protest against the petitioner, who has already been proclaimed winner, taken his oath, and assumed his duties, would be to usurp the functions of the House Electoral Tribunal. The alleged invalidity of the proclamation, despite irregularities and pending protests, is a matter for the Electoral Tribunal's sound judgment.
Ratio Decidendi
On the COMELEC's jurisdiction to annul proclamation after oath-taking and assumption of office: The Supreme Court held that once a candidate has been proclaimed winner, taken his oath of office, and assumed his duties as Congressman, the matter of an electoral protest against him falls under the exclusive jurisdiction of the House Electoral Tribunal. To allow the COMELEC to annul such a proclamation after these events would be to usurp the constitutional mandate of the Electoral Tribunal. The Court emphasized that the alleged invalidity of the proclamation, even with pending protests and alleged irregularities, is a matter that should be addressed by the Electoral Tribunal. The Court's intervention in such a scenario would constitute an encroachment upon the exclusive domain of the House Electoral Tribunal, as provided by Section 17, Article VI of the 1987 Constitution. Therefore, the COMELEC's act of revoking the proclamation was deemed an overreach of its authority in this context. On the Supreme Court taking cognizance of the electoral protest: The Supreme Court ruled that it should give due course to the petition because the petitioner had already been proclaimed the winner, taken his oath, and assumed his duties as Congressman. The Court reiterated that taking cognizance of the electoral protest against him would be an act of usurping the functions of the House Electoral Tribunal. The Court found the petition impressed with merit on this ground, as the issue of the proclamation's validity and the pending protests were matters within the competence of the Electoral Tribunal. The Court's role is to ensure that constitutional bodies, like the House Electoral Tribunal, are not divested of their exclusive jurisdiction. Thus, the Supreme Court's action was to uphold the constitutional framework governing election contests.
Main Doctrine
The Supreme Court has jurisdiction to review COMELEC resolutions concerning election proclamations, especially when the proclamation has been made, the oath taken, and office assumed, and the issue involves the COMELEC's authority to annul such proclamation, which may impinge upon the exclusive jurisdiction of the House Electoral Tribunal over election contests.