Lazatin v. House Electoral Tribunal
REITERATIONFacts
The Antecedents: Petitioner Carmelo F. Lazatin and private respondent Lorenzo G. Timbol were candidates for Representative of the first district of Pampanga in the May 11, 1987 elections. Private respondent filed objections during the canvassing, which led to a Commission on Elections (COMELEC) order to suspend proclamation, followed by another order to proceed. Petitioner was proclaimed on May 27, 1987. Private respondent filed petitions with the COMELEC to declare the proclamation void and to prohibit petitioner from assuming office. Petitioner assumed office on June 30, 1987. On September 15, 1987, the COMELEC declared petitioner's proclamation void ab initio. Petitioner challenged this in G.R. No. 80007, and this Court, on January 25, 1988, set aside the COMELEC's revocation. Procedural History: On February 8, 1988, private respondent filed an election protest (Case No. 46) with the House of Representatives Electoral Tribunal (HRET). Petitioner moved to dismiss, arguing it was filed late under Section 250 of the Omnibus Election Code. The HRET denied the motion, holding the protest was filed on time under Section 9 of its Rules. Petitioner's motion for reconsideration was also denied. The Petition: Petitioner filed a special civil action for certiorari and prohibition with the Supreme Court, seeking to annul the HRET's resolutions dated May 2, 1988 (holding the protest timely filed) and July 29, 1988 (denying reconsideration), arguing the HRET lacked jurisdiction due to the late filing of the protest.
Issue(s)
Whether the House Electoral Tribunal (HRET) acquired jurisdiction over the election protest filed by private respondent, and whether the election protest filed by private respondent was filed within the reglementary period. Whether the HRET has the power to promulgate its own rules regarding the period for filing election protests. Whether the Supreme Court can review the HRET's resolutions regarding the timeliness of the protest. Whether the Supreme Court can review the HRET's resolutions regarding the issuance of injunctive relief.
Ruling
The Supreme Court dismissed the petition, holding that the HRET acquired jurisdiction over the election protest because it was filed within the period prescribed by the HRET Rules. The Court also dismissed the private respondent's counter/cross-petition.
Ratio Decidendi
On the jurisdiction of the HRET and the timeliness of the protest: The Court held that the protest was filed on time. Petitioner's reliance on Section 250 of the Omnibus Election Code was misplaced because that provision applies only to petitions filed before the COMELEC. Furthermore, Section 250, as it pertains to Members of the Batasang Pambansa, had ceased to be effective under the 1987 Constitution due to the abolition of the Batasang Pambansa and the vesting of exclusive jurisdiction over election contests for Members of Congress in their respective Electoral Tribunals. The Court emphasized that the 1987 Constitution, under Article VI, Section 17, grants the Senate and the House of Representatives each an Electoral Tribunal as the sole judge of all contests relating to the election, returns, and qualifications of their respective Members. This grant of power is exclusive and comprehensive, intended to be as complete and unimpaired as if it had remained originally in the legislature. The HRET correctly interpreted its Rule 9, which provided a 15-day period from November 22, 1987, or from the date of proclamation if made prior to the effectivity of the rules. However, the HRET considered the COMELEC's September 15, 1987 resolution voiding the proclamation as having suspended the effect of the proclamation until January 28, 1988, when the Supreme Court's decision annulling the COMELEC resolution was received by the private respondent. Thus, the 15-day period was reckoned from January 28, 1988, making the protest filed on February 8, 1988, timely. On the HRET's rule-making power: The Court affirmed that the power of the HRET to promulgate rules and regulations relative to matters within its jurisdiction, including the period for filing election protests, is beyond dispute and flows from its constitutional grant of power as the sole judge of all contests relating to the election, returns, and qualifications of Members of the House of Representatives. This power is supported by historical precedents and jurisprudence, notably the landmark case of Angara v. Electoral Commission, which established that the creation of an electoral body carries with it the incidental power to promulgate necessary rules for the exercise of its exclusive jurisdiction. The Court reiterated that the framers of the 1987 Constitution intended to restore fully to the Electoral Tribunals exclusive jurisdiction over such contests, consonant with the separation of powers. While the provisions of the Omnibus Election Code on the conduct of elections were generally made applicable to the congressional elections, this did not necessarily imply the application of all its provisions to every aspect of the electoral exercise, particularly concerning the jurisdiction and procedural rules of the Electoral Tribunals. The Court found no provision in the Omnibus Election Code or related executive orders specifying the period for filing election protests before the Electoral Tribunals. Therefore, the HRET's own rules govern this aspect. On the HRET's interpretation of its rules and the timeliness of the protest: The HRET correctly interpreted its Rule 9, which provided a 15-day period from November 22, 1987, or from the date of proclamation if made prior to the effectivity of the rules. However, the HRET considered the COMELEC's September 15, 1987 resolution voiding the proclamation as having suspended the effect of the proclamation until January 28, 1988, when the Supreme Court's decision annulling the COMELEC resolution was received by the private respondent. Thus, the 15-day period was reckoned from January 28, 1988, making the protest filed on February 8, 1988, timely. On the private respondent's counter/cross-petition and the issuance of injunctive relief: The Court found the private respondent's prayer for injunctive relief to be without merit. The matter of issuing a restraining order or preliminary injunction lies within the sound discretion of the HRET. The Court reiterated that any final action taken by the HRET on matters within its jurisdiction is generally not subject to review by the Supreme Court, except upon a clear showing of grave abuse of discretion amounting to lack or excess of jurisdiction, which was not demonstrated in this case.
Main Doctrine
The House Electoral Tribunal (HRET) has the exclusive constitutional power to promulgate its own rules and regulations, including the period for filing election protests before it, which power is independent of statutory provisions like Section 250 of the Omnibus Election Code. Therefore, an election protest filed within the period prescribed by the HRET Rules is considered timely, and the HRET acquires jurisdiction over it.