Fernandez v. Commission on Elections
REITERATIONFacts
The Antecedents: In the July 15, 2002 synchronized barangay and Sangguniang Kabataan (SK) Elections, respondent Mark Anthony B. Rodriguez was declared the winning candidate for SK chairman of Barangay Pandan del Sur, Pandan, Catanduanes, with 27 votes over petitioner Indira R. Fernandez's 25 votes. Procedural History: Petitioner instituted an election protest with the 4th Municipal Circuit Trial Court (MCTC). The MCTC, after revision, declared petitioner the duly elected SK chairman with 29 votes against respondent's 24 votes. Respondent appealed to the Commission on Elections (COMELEC). The Petition: The COMELEC First Division, in a Resolution dated December 4, 2006, nullified the MCTC's decision, ruling that three ballots credited to petitioner were tampered and should be admitted for the original candidate (Rodriguez). This resulted in 26 votes for petitioner and 27 for respondent. The COMELEC First Division, in an Order dated January 31, 2007, denied petitioner's motion for reconsideration for being filed out of time. Petitioner filed the instant petition for certiorari and prohibition, assailing the COMELEC's resolution and order, arguing that the COMELEC lacked appellate jurisdiction and gravely abused its discretion.
Issue(s)
Whether the Commission on Elections (COMELEC) has appellate jurisdiction over election contests involving Sangguniang Kabataan (SK) officials decided by trial courts of limited jurisdiction. Whether the COMELEC gravely abused its discretion in nullifying the decision of the trial court; and whether the issue is moot because the term of the contested office has expired.
Ruling
The Supreme Court dismissed the petition for certiorari and prohibition. The Court ruled that the case had become moot and academic due to the expiration of the term of the contested office. However, for the guidance of the bench and the bar, the Court discussed the issue of jurisdiction.
Ratio Decidendi
On the issue of COMELEC's appellate jurisdiction: The Court clarified that the 1987 Constitution vests in the COMELEC appellate jurisdiction over all contests involving elective barangay officials decided by trial courts of limited jurisdiction. In relation to Republic Act No. 7160, which includes the SK chairman in the enumeration of barangay officials, the constitutional provision sanctions the appellate review by the COMELEC of election protests involving the position of SK chairman. Thus, the COMELEC's assumption of jurisdiction over the respondent's appeal was proper. The Court also noted that the ruling in Mercado v. Board of Election Supervisors was no longer controlling, and the current rule is that trial courts have exclusive original jurisdiction over election protests involving barangay officials, including SK chairmen, and the COMELEC has exclusive appellate jurisdiction over such protests. On the issue of mootness and grave abuse of discretion: The Court held that the petition had become moot and academic because the term of the contested office, that of SK chairman, had already expired. Republic Act No. 9164, as amended by R.A. 9340, stipulated the terms of SK officials. The term for those elected in 2002 ended on November 30, 2007. Therefore, any judgment rendered by the Court would have no practical legal effect or could no longer be enforced, rendering the review of the records and the discussion of legal principles an exercise in futility. The question of grave abuse of discretion is rendered moot by the expiration of the term.
Main Doctrine
The Supreme Court dismissed a petition for certiorari and prohibition assailing a COMELEC resolution on an election protest involving an SK chairman, ruling that the case had become moot and academic due to the expiration of the contested office's term. The Court also clarified that the COMELEC possesses exclusive appellate jurisdiction over election contests involving barangay officials, including SK chairmen, decided by trial courts of limited jurisdiction.