Beso v. Aballe
REITERATIONFacts
The Antecedents: Petitioner Vito Beso (BESO) and private respondent Rita Aballe (ABALLE) were candidates for Barangay Captain of Barangay Carayman, Calbayog City. BESO garnered 495 votes, while ABALLE obtained 496 votes, leading to ABALLE's proclamation. BESO filed an election protest with the Municipal Trial Court of Calbayog City (MTCC), which ruled in favor of BESO, reversing ABALLE's proclamation and declaring BESO the duly elected Punong Barangay. Procedural History: ABALLE appealed the MTCC decision to the Regional Trial Court (RTC) and the Commission on Elections (COMELEC). The MTCC granted BESO's motion for execution pending appeal, which ABALLE sought to reconsider. ABALLE then filed a special civil action for certiorari and prohibition with the RTC against the MTCC Judge, seeking to annul the orders denying her motion for inhibition and granting the execution pending appeal. The RTC issued a temporary restraining order (TRO) and later made it permanent, setting aside and vacating the MTCC's writ of execution pending appeal, ruling that the MTCC had lost jurisdiction. BESO's motion for reconsideration was denied. The Petition: BESO filed a petition for certiorari with the Supreme Court, asserting that the RTC Judge acted without jurisdiction and with grave abuse of discretion in issuing the TROs, the decision, and the order denying reconsideration. He prayed for the nullification of these issuances. Meanwhile, the COMELEC received the records of the election protest and docketed it as EAC No. 95-98.
Issue(s)
Whether the Regional Trial Court (RTC) acted without jurisdiction and with grave abuse of discretion in entertaining the petition for certiorari and prohibition filed by respondent Rita Aballe. Whether the RTC correctly ruled that the Municipal Trial Court (MTC) had lost jurisdiction to issue a writ of execution pending appeal.
Ruling
The Supreme Court GRANTED the petition, SET ASIDE and NULLIFIED the challenged orders and decision of respondent Judge Roberto A. Navidad of the RTC, and ordered the RTC to DISMISS Special Civil Action No. 98-040. The Court held that the RTC acted without jurisdiction and with grave abuse of discretion amounting to lack of jurisdiction.
Ratio Decidendi
On whether the Regional Trial Court (RTC) acted without jurisdiction and with grave abuse of discretion in entertaining the petition for certiorari and prohibition filed by respondent Rita Aballe: The Supreme Court ruled that the RTC acted without jurisdiction and with grave abuse of discretion. The Court emphasized that since ABALLE had appealed the MTCC decision to the COMELEC, the COMELEC possessed primary jurisdiction over the case, including the issuance of extraordinary writs in aid of its appellate jurisdiction. This principle was established in Relampagos v. Cumba, et al., where it was held that the COMELEC has exclusive authority to hear and decide petitions for certiorari, prohibition, and mandamus involving election cases, especially when it has exclusive appellate jurisdiction, as is the case with barangay election contests. Therefore, the RTC should not have entertained ABALLE's petition, as it encroached upon the COMELEC's exclusive domain. The allegation that it was impossible for ABALLE to invoke the COMELEC's power due to the records being forwarded late was deemed without merit, as certified copies of challenged resolutions could have been obtained. On whether the RTC correctly ruled that the Municipal Trial Court (MTC) had lost jurisdiction to issue a writ of execution pending appeal: The Supreme Court found that the RTC's reasoning was flawed in its conclusion that the MTCC had lost jurisdiction. While ABALLE did perfect her appeal within the reglementary period, the MTCC's issuance of a writ of execution pending appeal was a matter within its discretion and jurisdiction at the time it was granted, prior to the COMELEC's assumption of appellate jurisdiction. The core issue was not whether the MTCC lost jurisdiction to decide the protest, but whether the RTC had jurisdiction to review the MTCC's interlocutory order of execution pending appeal via a petition for certiorari. The Supreme Court clarified that the COMELEC, not the RTC, has the exclusive appellate jurisdiction over election protests involving barangay officials, and thus, any challenge to the MTCC's orders in such a case should have been filed with the COMELEC. The RTC's assumption of jurisdiction over the certiorari petition was an error, rendering its subsequent orders and decision void.
Main Doctrine
The Commission on Elections (COMELEC) has exclusive appellate jurisdiction over election contests involving elective barangay officials decided by trial courts of limited jurisdiction, and may issue extraordinary writs in aid of its appellate jurisdiction. Consequently, a Regional Trial Court (RTC) acts without jurisdiction and with grave abuse of discretion when it entertains a petition for certiorari and prohibition to annul an execution pending appeal granted by a Municipal Trial Court (MTC) in an election protest case.