Edding v. Commission on Elections
ABANDONMENTFacts
The Antecedents: During the May 1992 elections, Norbi H. Edding and Pablo S. Bernardo contested the mayoralty of Sibuco, Zamboanga del Norte. Bernardo was initially proclaimed the winner by 212 votes. Edding filed an election protest in the Regional Trial Court (RTC) of Sindangan, Zamboanga del Norte, alleging massive fraud. On July 2, 1993, the RTC rendered a decision declaring Edding the winner and nullifying Bernardo's election. Procedural History: On July 8, 1993, Bernardo filed a Notice of Appeal, while Edding simultaneously moved for immediate execution of the judgment. On July 13, 1993, the RTC granted Edding's motion for immediate execution, leading Edding to assume office on July 15, 1993. Bernardo then filed a Petition for Certiorari with the Commission on Elections (COMELEC) (SPR No. 5-93) to enjoin the RTC's execution order. On September 23, 1994, the COMELEC issued an order granting a preliminary injunction, directing the RTC judge to cease enforcing the execution and ordering Edding to vacate the office. The Petition: Edding filed a Special Civil Action for Certiorari and Prohibition with the Supreme Court, assailing the COMELEC's jurisdiction. Edding argued that under the prevailing doctrines of Garcia v. De Jesus and Uy v. COMELEC, the COMELEC lacks the power to issue writs of certiorari. He further contended that the RTC retained jurisdiction to order execution pending appeal despite the filing of a notice of appeal.
Issue(s)
Whether the Commission on Elections (COMELEC) has jurisdiction to issue writs of certiorari, prohibition, and mandamus in election cases. Whether the Regional Trial Court (RTC) is divested of jurisdiction to resolve a motion for execution pending appeal upon the filing of a notice of appeal. Whether the expiration of the contested term of office renders the petition moot.
Ruling
The Supreme Court DISMISSED the petition for being moot and academic, while clarifying that the Commission on Elections (COMELEC) does have certiorari jurisdiction and the Regional Trial Court (RTC) did not abuse its discretion in granting execution pending appeal.
Ratio Decidendi
On Issue 1: The Supreme Court held that the Commission on Elections (COMELEC) has the authority to issue extraordinary writs of certiorari, prohibition, and mandamus in aid of its appellate jurisdiction. In doing so, the Court explicitly abandoned the previous rulings in Garcia v. De Jesus, Uy v. COMELEC, and Veloria v. COMELEC. The Court reasoned that Section 50 of Batas Pambansa Blg. 697 (B.P. Blg. 697), which expressly grants this power, remains in full force and effect. The Court clarified that the Omnibus Election Code (B.P. Blg. 881) did not repeal Section 50 of B.P. Blg. 697 because the repealing clause in the Code was merely a general one and there was no inconsistency between the two laws. This jurisdiction is essential to prevent the splitting of jurisdiction and to expedite the disposition of election cases. On Issue 2: The Court ruled that the Regional Trial Court (RTC) did not commit grave abuse of discretion in granting the motion for immediate execution. It established that the mere filing of a notice of appeal does not automatically divest the trial court of its jurisdiction to resolve pending incidents, such as a motion for execution pending appeal, provided the motion was filed within the reglementary period. Since Edding filed his motion for execution on the same day Bernardo filed his notice of appeal, the RTC retained the competence to hear and resolve the motion. The Court emphasized that the trial court must resolve such motions as they become part of the records to be elevated on appeal. Consequently, the COMELEC's order enjoining the RTC's execution was technically erroneous. On Issue 3: The Court ultimately dismissed the petition because the term of office for the disputed mayoralty seat was set to expire on June 30, 1995. Additionally, the elections for the subsequent term had already been concluded by the time the case was decided. Under Philippine jurisprudence, when the term of the contested office expires, the controversy becomes moot and academic as there is no longer a practical relief that can be granted. While the Court took the opportunity to settle the jurisdictional conflict regarding the COMELEC's powers, the specific dispute between Edding and Bernardo could no longer be resolved with any legal effect on the possession of the office.
Main Doctrine
The Commission on Elections (COMELEC) possesses the jurisdiction to issue extraordinary writs of certiorari, prohibition, and mandamus in aid of its appellate jurisdiction. This authority is derived from Section 50 of Batas Pambansa Blg. 697 (B.P. Blg. 697), which was not repealed by the Omnibus Election Code (B.P. Blg. 881) and was not rendered functus officio after the 1984 elections. This power allows the COMELEC to review interlocutory orders issued by Regional Trial Courts (RTC) in election protests involving municipal and barangay officials, ensuring a unified system of election justice.