Dueñas v. Reyes
REITERATIONFacts
The Antecedents: Henry "Jun" Dueñas, Jr. and Angelito "Jett" P. Reyes were rival candidates for congressman in Taguig City. Dueñas was proclaimed winner. Reyes filed an election protest, praying for revision/recount in 1707 of 732 precincts. Dueñas filed an answer and counter-protested 560 precincts, alleging fraud against him. Procedural History: The House of Representatives Electoral Tribunal (HRET) ordered the collection of election materials. Parties agreed to revise all protested precincts as they constituted less than 50% of the total. Revision began, covering 100% of protested precincts and 25% of counter-protested precincts. During revision, fake/spurious ballots were discovered. The HRET ordered the continuation of revision for the remaining 75% of counter-protested precincts, citing the need to ascertain the true will of the electorate and the discovery of fake ballots. Dueñas moved for reconsideration, which was denied. The HRET then ordered Dueñas to augment his cash deposit for the revision expenses. Instead, Dueñas filed a motion to withdraw/abandon the remaining 75% counter-protested precincts. The HRET denied this motion and ordered the use of its own funds for the revision. The Petition: Dueñas filed a petition for certiorari, alleging that the HRET committed grave abuse of discretion in denying his motion to withdraw and in ordering the use of its own funds for the revision.
Issue(s)
Whether the HRET committed grave abuse of discretion in denying petitioner's motion to withdraw or abandon his remaining 75% counter-protested precincts. Whether the HRET committed grave abuse of discretion in ordering that its own funds be used for the revision of ballots from the remaining 75% counter-protested precincts.
Ruling
The petition is dismissed. Resolution No. 08-353 dated November 27, 2008, of the House of Representatives Electoral Tribunal is affirmed.
Ratio Decidendi
On the denial of the motion to withdraw/abandon counter-protest: The Supreme Court held that the HRET did not commit grave abuse of discretion. The HRET, as the sole judge of election contests involving members of the House of Representatives, has exclusive and exhaustive jurisdiction. Rule 88 of the HRET Rules grants the Tribunal the discretion to continue or discontinue revision proceedings motu proprio. The discovery of fake/spurious ballots provided a sufficient and legitimate reason for the HRET to continue the revision to ascertain the true will of the electorate. Petitioner's argument that the HRET was speculating or assisting the protestant was unfounded, as his own position was based on conjectures. The Court emphasized that it cannot substitute its judgment for that of the HRET on technical matters within the Tribunal's exclusive prerogative. Jurisdiction, once acquired, is not lost at the instance of the parties but continues until the case is terminated. On the use of HRET's own funds for revision: The Supreme Court ruled that the HRET did not commit grave abuse of discretion. When jurisdiction is conferred by law, the tribunal is deemed to have the authority to employ all necessary means to make its power effective. Rule 7 of the HRET Rules grants the Tribunal exclusive control over its functions and operations. Rule 8 provides for express and implied powers necessary or incidental to its purposes. The HRET's budget under RA 9498 (General Appropriations Act for Fiscal Year 2008) was sufficient for adjudicating electoral contests. The use of its own funds was an exercise of its inherent power and discretion to ensure the ascertainment of the true will of the electorate, which is a matter of public interest. Rule 33 of the HRET Rules also allows the Tribunal to take equitable action if a party fails to make required deposits. The Court reiterated that grave abuse of discretion requires a showing of capricious, whimsical, arbitrary, or despotic exercise of judgment, which was not demonstrated by the petitioner.
Main Doctrine
The Supreme Court will not interfere with the electoral tribunal's exercise of discretion in election contests, particularly concerning the continuation of ballot revision, unless there is a clear showing of grave abuse of discretion amounting to lack or excess of jurisdiction. The tribunal's inherent power to ascertain the true will of the electorate allows it to use its own funds for revision proceedings when necessary.