Guerrero v. Commission on Elections
REITERATIONFacts
The Antecedents: Guillermo C. Ruiz filed a petition with the Commission on Elections (COMELEC) seeking to disqualify Rodolfo C. Fariñas as a candidate for Congressman in the first district of Ilocos Norte for allegedly campaigning without filing a Certificate of Candidacy (CoC), violating Section 73 of the Omnibus Election Code. Ruiz sought to declare Fariñas a "nuisance candidate" under Section 69 of the Omnibus Election Code. Procedural History: On May 8, 1998, Fariñas filed his CoC, substituting for Chevylle V. Fariñas who had withdrawn. On May 10, 1998, the COMELEC Second Division dismissed Ruiz's petition, stating there was no CoC to cancel and thus no candidate to disqualify. The elections proceeded on May 11, 1998, with Fariñas winning and being proclaimed. Ruiz filed a motion for reconsideration, arguing Fariñas could not validly substitute an independent candidate. Arnold V. Guerrero, an opposing candidate, filed a petition-in-intervention, asserting Fariñas' CoC was defective for failing to meet substitution requirements under Section 77 of the Omnibus Election Code. On January 6, 1999, the COMELEC En Banc affirmed the dismissal, stating it lacked jurisdiction after Fariñas assumed office, without prejudice to a quo warranto case. The Petition: Petitioner Arnold V. Guerrero filed a petition for certiorari, prohibition, and mandamus, assailing the COMELEC's dismissal of Ruiz's petition and Guerrero's intervention, arguing the COMELEC committed grave abuse of discretion by refusing to rule on the validity of Fariñas' candidacy and by deferring to the House of Representatives Electoral Tribunal (HRET).
Issue(s)
Whether the COMELEC committed grave abuse of discretion in holding that the determination of the validity of the certificate of candidacy of respondent Fariñas is within the exclusive jurisdiction of the Electoral Tribunal of the House of Representatives. Whether the COMELEC acted without or in excess of jurisdiction in refusing to rule on the validity or invalidity of the candidacy or purported certificate of candidacy of respondent Fariñas. Whether the COMELEC acted without or in excess of jurisdiction in tossing the duty to rule on the validity or invalidity of the candidacy or purported certificate of candidacy of respondent Fariñas to the House of Representatives Electoral Tribunal (HRET). Whether the COMELEC acted without or in excess of jurisdiction in not rendering a ruling disqualifying respondent Fariñas based on its findings. Whether the COMELEC acted without or in excess of jurisdiction in not calling a special election.
Ruling
The petition is DISMISSED for lack of merit. Costs against petitioner.
Ratio Decidendi
On the COMELEC's jurisdiction and grave abuse of discretion: The Court found no grave abuse of discretion on the part of the COMELEC. The COMELEC correctly held that its jurisdiction over the case ceased with the assumption of office by respondent Fariñas as a Member of the 11th Congress. Article VI, Section 17 of the Constitution vests the House of Representatives Electoral Tribunal (HRET) with the sole and exclusive jurisdiction over all contests relating to the election, returns, and qualifications of its Members. Therefore, once a winning candidate is proclaimed, takes an oath, and assumes office, the COMELEC's jurisdiction ends, and the HRET's jurisdiction begins. This deference to the HRET avoids duplicity of proceedings and potential clashes of jurisdiction between constitutional bodies, respecting the people's mandate. On the scope of HRET's jurisdiction: The petitioner's argument that the HRET's jurisdiction is limited to constitutional qualifications under Article VI, Section 6 of the Constitution, and thus excludes statutory qualifications like the filing of a certificate of candidacy, was found to lack cogency. The Court applied the principle of statutory construction, "Ubi lex non distinguit noc nos distinguire debemos" (where the law does not distinguish, we should not distinguish). The term "qualifications" in Article VI, Section 17 of the Constitution should not be read as qualified by the term "constitutional." The intent of the lawgivers was to grant the HRET broad jurisdiction over all matters concerning the election, returns, and qualifications of its members, without distinction. On the effect of a void proclamation: The petitioner's contention that a proclamation based on a void certificate of candidacy is void ab initio, thereby retaining COMELEC jurisdiction, was also rejected. The Court reiterated its ruling in Lazatin v. Commission on Elections that in an electoral contest where the validity of a proclamation of a winning candidate who has taken his oath of office and assumed his post is raised, that issue is best addressed to the HRET. This ensures that electoral tribunals are the primary arbiters of such disputes, preventing parallel proceedings. On the validity of substitution and candidacy: The Court held that the question of whether respondent Fariñas validly substituted Chevylle V. Fariñas and whether he became a legitimate candidate are matters that must likewise be addressed to the sound judgment of the Electoral Tribunal. This is in line with the constitutional mandate that the Electoral Tribunal is the "sole judge" of all contests relating to the election, returns, and qualifications of its members. The Court emphasized that only by deferring to the HRET can fealty to this constitutional provision be demonstrated. On the COMELEC's duty to call a special election: Since the COMELEC correctly divested itself of jurisdiction over the validity of Fariñas' candidacy upon his assumption of office, it logically followed that it also lost jurisdiction to declare the position vacant or to call for special elections based on the alleged invalidity of his candidacy. Such matters fall within the purview of the HRET.
Main Doctrine
Once a winning candidate has been proclaimed, taken his oath, and assumed office as a Member of the House of Representatives, the COMELEC's jurisdiction over election contests relating to his election, returns, and qualifications ends, and the House of Representatives Electoral Tribunal's (HRET) own jurisdiction begins.