Bustos v. Moir
REITERATIONFacts
1. The Antecedents: The underlying dispute concerned an election for an unspecified office where 319 votes were cast. A significant portion of these votes, 268, were cast by illiterate or physically unable individuals. The ballots for these voters were prepared by election inspectors without the oath required by the Election Law for such assistance. 2. Procedural History: Following the casting of these votes, an election contest was initiated. The Court of First Instance of Pampanga, presided over by respondent Judge Percy M. Moir, heard the contest. After reviewing the evidence, the court declared the ballots cast by illiterates and those assisted by inspectors without the proper oath as illegal and consequently annulled the entire election. 3. The Petition: Petitioner Gabino Bustos filed a petition for a writ of certiorari with the Supreme Court. The petition argued that the respondent judge acted without or in excess of his jurisdiction by annulling the election based on the illegal ballots. Bustos sought a revision and annulment of the lower court's proceedings. The Supreme Court, however, denied the petition, holding that the Court of First Instance had exclusive jurisdiction over election contests and the authority to annul an election, and that certiorari is not a remedy for correcting errors of law or fact within a court's jurisdiction.
Issue(s)
Whether the Court of First Instance acted without or in excess of its jurisdiction in annulling an election based on the finding that a significant number of ballots were illegally prepared by election inspectors for illiterate voters without the required oath. Whether a writ of certiorari is the proper remedy to correct alleged errors of judgment by a Court of First Instance in an election contest.
Ruling
The petition for a writ of certiorari is denied. The Supreme Court held that the Court of First Instance did not act without or in excess of its jurisdiction in annulling the election. The Court found that the respondent judge had the jurisdiction to hear and determine election contests, including the authority to annul an election in a proper case.
Ratio Decidendi
On Issue 1: The Court held that the Court of First Instance did not act without or in excess of its jurisdiction in annulling the election. Under the Election Law, the proper Court of First Instance possesses exclusive jurisdiction to hear and determine election contests. This jurisdiction includes the authority to recount ballots, reject illegal votes, accept valid votes, and, in a proper case, annul the election entirely. The fact that the court annulled the election, even if it were considered an error, does not divest it of jurisdiction. The power to decide a case includes the power to decide it wrongly, and such an error is not a ground for certiorari. The Court cited numerous cases to support the principle that certiorari is not a remedy for correcting errors of judgment. On Issue 2: The Court affirmed that a writ of certiorari is not a proceeding to correct errors of judgment. Instead, it is designed to relieve persons from arbitrary acts of courts and judges, meaning acts that they have no legal authority or power to perform. Errors of judgment, if an appeal lies, are correctible by appeal. In cases where no appeal is provided by law, such as in election contests, errors must be borne by the parties. The Court emphasized that interfering with the exclusive jurisdiction of the Court of First Instance in election contests through certiorari would violate the legislative intent and the statutory grant of exclusive jurisdiction without appeal.
Main Doctrine
The Supreme Court reiterated that a writ of certiorari is not a remedy for correcting errors of law or fact committed by a lower court acting within its jurisdiction. Certiorari is an extraordinary remedy specifically designed to address acts performed without or in excess of jurisdiction, or with grave abuse of discretion amounting to a lack or excess of jurisdiction. The Court emphasized that the mere fact that a court decides a question wrongly does not mean it acted without jurisdiction, as the power to decide includes the power to decide wrongly.