Sahali v. Commission on Elections
REITERATIONFacts
The Antecedents: Petitioner Sadikul Sahali and respondent Hadja Jubaida H. Matba were candidates for governor in Tawi-Tawi during the May 11, 1998 elections. Following the election, the Provincial Board of Canvassers proclaimed petitioner Sahali as the duly elected governor. The election process utilized the Automated Election System, as authorized by Republic Act No. 8436. However, prior to petitioner's assumption of office, the Commission on Elections (COMELEC) issued a resolution directing a manual recount of ballots in Tawi-Tawi and suspending the effects of the proclamation. Procedural History: Respondent Matba, along with Ismael B. Abubakar, Jr., had filed a petition (SPA No. 98-349) with the COMELEC on May 22, 1998, alleging massive system breakdowns in the automated counting machines, leading to various discrepancies and errors. In response, the COMELEC issued Minute Resolution No. 98-1959 on June 29, 1998, ordering a manual recount and suspending the proclamation. Petitioner Sahali subsequently filed a special civil action for certiorari with the Supreme Court on July 3, 1998, seeking to annul the COMELEC resolution. The Supreme Court issued a status quo ante order on July 14, 1998. The Office of the Solicitor General opined that the COMELEC should have conducted a hearing. The COMELEC itself later issued Minute Resolution No. 98-2145 on July 14, 1998, holding Minute Resolution No. 98-1959 in abeyance, and subsequently Minute Resolution No. 98-2828 on October 15, 1998, clarifying that the proclaimed candidates, including Sahali, were the duly elected officials at the time of the status quo ante order. The Petition: Petitioner Sahali filed a petition for certiorari under Rule 65 of the Rules of Court, assailing COMELEC Minute Resolution No. 98-1959. He argued that he was denied due process as he was not notified of the petition in SPA No. 98-349 nor of the promulgation of the assailed resolution. Petitioner contended that his right to assume office is a property right protected by due process and that the COMELEC resolution was void for lack of a pre-proclamation controversy and proper notice and hearing. He also argued that the COMELEC erred in extending the petition's effect beyond the deadline for assuming office. The Supreme Court, however, found the petition moot and academic due to the COMELEC's subsequent resolutions that effectively recalled or held in abeyance the assailed resolution, and noted that a similar petition in G.R. No. 134188 had already been dismissed.
Issue(s)
Whether the COMELEC committed grave abuse of discretion amounting to lack or excess of jurisdiction in issuing Minute Resolution No. 98-1959 without prior notice and hearing to the petitioner. Whether the petition for certiorari is moot and academic due to subsequent COMELEC resolutions and Supreme Court orders; and the nature of Certiorari.
Ruling
The petition is DISMISSED. The Supreme Court found that the issue had become moot and academic due to supervening events, specifically COMELEC Minute Resolution No. 98-2145 which held in abeyance the implementation of Minute Resolution No. 98-1959, and COMELEC Minute Resolution No. 98-2828 which clarified that the proclaimed candidates, including petitioner Sahali, were the duly elected officials. The Court also noted that certiorari is not a remedy for errors of judgment but only for errors of jurisdiction or grave abuse of discretion.
Ratio Decidendi
On the issue of grave abuse of discretion and due process: The petitioner failed to demonstrate that the COMELEC's issuance of Minute Resolution No. 98-1959 constituted a capricious, arbitrary, or whimsical exercise of power equivalent to lack of jurisdiction. While the petitioner claimed denial of due process for lack of notice and hearing, the COMELEC, in its subsequent Minute Resolution No. 98-2145 dated July 14, 1998, held in abeyance the implementation of the assailed resolution. This action indicated that the COMELEC reconsidered its earlier resolution, negating any finding of grave abuse of discretion. The COMELEC has the inherent power to amend and control its processes and orders, and it exercised this power by recalling or suspending the effect of Minute Resolution No. 98-1959 before it became final and executory. On the issue of mootness and the nature of Certiorari: The petition was rendered moot and academic by subsequent events. The COMELEC itself, through Minute Resolution No. 98-2145, held in abeyance the implementation of Minute Resolution No. 98-1959. Furthermore, Minute Resolution No. 98-2828 clarified that petitioner Sadikul Sahali and other proclaimed local candidates were the duly elected officials at the time of the Supreme Court's status quo ante order. This subsequent action by the COMELEC effectively withdrew or suspended the effects of the resolution that the petitioner sought to annul, making the petition for certiorari no longer justiciable. The Supreme Court reiterated the principle that courts should refrain from passing upon issues that have become moot and academic, as an adjudication would serve no practical purpose. The Court emphasized that a special civil action for certiorari under Rule 65 is available only to correct errors of jurisdiction or grave abuse of discretion, not mere errors of judgment, procedure, or misappreciation of facts and evidence. The petitioner must clearly show that the COMELEC acted without or in excess of its jurisdiction, or with grave abuse of discretion that is patent and gross, amounting to an evasion of a positive duty or a virtual refusal to perform a duty enjoined by law. The petitioner failed to meet this stringent requirement, as the COMELEC's subsequent actions demonstrated a correction of its process rather than an arbitrary exercise of power.
Main Doctrine
A petition for certiorari seeking to annul a COMELEC resolution that was subsequently recalled or held in abeyance by the COMELEC itself, rendering the issue moot and academic, must be dismissed. The COMELEC has the power to amend or control its processes and orders, and can recall a resolution before it becomes final and executory. Certiorari will only issue to correct errors of jurisdiction, not errors of procedure or mistakes in findings of fact or conclusions of law.