Roces v. House of Representatives Electoral Tribunal
REITERATIONFacts
The Antecedents: Petitioner Miles Andrew Mari Roces and the late Harry Ang Ping filed certificates of candidacy for Representative of the 3rd Congressional District of Manila in the May 2004 elections. A registered voter questioned Mr. Ang Ping's candidacy before the Commission on Elections (COMELEC) due to alleged misrepresentation of his citizenship. Subsequently, Mr. Ang Ping filed a withdrawal of his certificate of candidacy, and his wife, Maria Zenaida B. Ang Ping, sought to substitute for him. Procedural History: The COMELEC First Division issued a resolution on April 30, 2004, granting the petition to deny due course to Mr. Ang Ping's certificate of candidacy, despite his subsequent withdrawal and motion to dismiss. This resolution was purportedly promulgated on April 30, 2004, though notice of promulgation was for May 5, 2004, and the resolution was served on May 8, 2004. The COMELEC en banc, on May 8, 2004, issued Resolution No. 6823, declaring Mr. Ang Ping's withdrawal moot, denying his wife's substitution, and ordering his name deleted from the list of candidates. This resolution was used by the Manila City Board of Canvassers to not canvass votes for the Ang Pings, leading to Roces' proclamation as winner. The Ang Pings appealed to the COMELEC en banc and filed an election protest ad cautelam with the House of Representatives Electoral Tribunal (HRET). This Court dismissed the Ang Pings' petition for certiorari concerning COMELEC Resolution No. 6823 due to the pending HRET protest. The HRET later converted the ad cautelam protest to a regular protest and denied Roces' motion to dismiss. The Petition: Roces filed the present petition for certiorari with this Court, assailing the HRET's resolutions denying his motion to dismiss. He argues that the HRET committed grave abuse of discretion in ruling that Mrs. Ang Ping is a proper party to file the election protest, given the COMELEC's denial of her husband's certificate of candidacy, and questions the HRET's jurisdiction to review COMELEC resolutions. The core of Roces' argument is that COMELEC decisions are exclusively reviewable by the Supreme Court via certiorari and that the HRET cannot collaterally attack these decisions.
Issue(s)
Whether the House of Representatives Electoral Tribunal (HRET) committed grave abuse of discretion in ruling that Maria Zenaida B. Ang Ping was a proper party to file an election protest despite the COMELEC resolutions denying her substitution. Whether the House of Representatives Electoral Tribunal (HRET) has the jurisdiction to review, declare void, or disregard resolutions issued by the Commission on Elections (COMELEC).
Ruling
The petition is dismissed. The temporary restraining order previously issued by the Court is lifted.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the House of Representatives Electoral Tribunal (HRET) did not commit grave abuse of discretion because, under Article VI, Section 17 of the 1987 Constitution, it is the 'sole judge' of all contests relating to the election, returns, and qualifications of its members. This exclusive jurisdiction necessarily includes the power to determine whether it has the authority to hear a case, which involves verifying if the proper parties are present. The HRET's determination that Mrs. Ang Ping was a proper party was an exercise of this constitutional mandate. The Court noted that Mrs. Ang Ping was a candidate voted for on election day and that the COMELEC's attempt to disqualify her was procedurally flawed. Therefore, the HRET acted within its bounds when it allowed the protest to proceed to ensure that the will of the electorate was not frustrated by procedural anomalies. On Issue 2: The Court held that while COMELEC decisions are generally reviewed by the Supreme Court via certiorari, a void judgment or resolution may be impeached through a collateral attack in any tribunal. The COMELEC resolutions in question were found to be void ab initio because they violated Mrs. Ang Ping's right to due process. Specifically, the First Division's resolution was 'promulgated' on a date different from the one officially noticed, and the En Banc prematurely assumed jurisdiction before the reglementary period for reconsideration had lapsed. Since these resolutions were void, they had no legal effect and could be disregarded by the HRET. Furthermore, since Roces himself introduced these resolutions as evidence to support his motion to dismiss, he submitted their validity to the HRET's scrutiny. The HRET did not 'usurp' COMELEC's jurisdiction but rather performed its duty to evaluate the evidence and determine its own jurisdiction over the protest.
Main Doctrine
The House of Representatives Electoral Tribunal (HRET) possesses the inherent authority to determine its own jurisdiction, which includes the power to decide whether a party has the personality to file an election protest. When a party's standing is challenged based on Commission on Elections (COMELEC) resolutions that are void ab initio due to blatant violations of procedural due process—such as irregular promulgation and premature assumption of jurisdiction by the En Banc—the HRET may disregard or declare such resolutions inoperative. A void judgment has no legal effect and can be impeached through a collateral attack in any tribunal in which effect is sought to be given to it.