Tañada v. Commission on Elections
REITERATIONFacts
The Antecedents: Wigberto R. Tañada, Jr., Angelina D. Tan, and Alvin John S. Tañada were candidates for the position of Member of the House of Representatives for the 4th District of Quezon Province in the May 13, 2013 National Elections. Wigberto filed petitions to cancel Alvin John's Certificate of Candidacy (CoC) and to declare him a nuisance candidate. Procedural History: The Commission on Elections (COMELEC) First Division initially dismissed Wigberto's petitions. However, the COMELEC En Banc, while upholding the dismissal of the nuisance candidate petition, granted the motion for reconsideration on the petition to cancel Alvin John's CoC, finding material misrepresentations regarding residency. Despite the cancellation of Alvin John's CoC, his name remained on the ballot. The Provincial Board of Canvassers denied Wigberto's motion to credit Alvin John's votes to him, leading to Angelina's proclamation. Wigberto subsequently filed an election protest ad cautelam before the House of Representatives Electoral Tribunal (HRET) and a petition to annul Angelina's proclamation, which was pending before the COMELEC En Banc. The Petition: Wigberto assails the COMELEC En Banc Resolution declaring Alvin John not a nuisance candidate via a petition for certiorari under Rule 65 in relation to Rule 64 of the Rules of Court. He seeks to have Alvin John's votes credited to him and to be declared the winning candidate. However, the Court notes that Angelina has been proclaimed and has assumed office, divesting the COMELEC of jurisdiction in favor of the HRET, which has sole jurisdiction over contests relating to election, returns, and qualifications of Members of the House of Representatives.
Issue(s)
Whether the Supreme Court has jurisdiction to resolve the petition for certiorari assailing the COMELEC En Banc Resolution declaring Alvin John not a nuisance candidate, given that Angelina had already been proclaimed as the winning candidate and had assumed office. Whether Alvin John S. Tañada is a nuisance candidate under Section 69 of the Omnibus Election Code (OEC), but considering the HRET's exclusive jurisdiction after proclamation.
Ruling
The petition is DISMISSED for lack of jurisdiction. The Supreme Court is without jurisdiction to resolve the case as the proclamation of Angelina D. Tan as Member of the House of Representatives for the 4th District of Quezon Province divested the COMELEC of jurisdiction over disputes relating to the election, returns, and qualifications of the proclaimed representative in favor of the House of Representatives Electoral Tribunal (HRET).
Ratio Decidendi
On the issue of jurisdiction: The Court held that Section 17, Article VI of the 1987 Philippine Constitution designates the HRET as the sole judge of all contests relating to the election, returns, and qualifications of Members of the House of Representatives. Case law establishes that once a congressional candidate is proclaimed, the COMELEC's jurisdiction over disputes concerning the election, returns, and qualifications of the proclaimed representative is divested in favor of the HRET. The terms "election," "returns," and "qualifications" encompass all matters affecting the validity of a contestee's title, including the conduct of polls, canvass of returns, proclamation of winners, and issues concerning eligibility or inadequacy of the CoC. In this case, Angelina had already been proclaimed on May 16, 2013, and had assumed office. Therefore, any issues concerning the conduct of the canvass and the resulting proclamation fall under the HRET's exclusive jurisdiction, rendering the Supreme Court without jurisdiction to resolve the present petition for certiorari. The Court emphasized that the "election, returns, and qualifications" phrase pertains to all matters that could affect the validity of the proclaimed winner's title to the office. Consequently, the petition assailing the COMELEC's resolution on the nuisance candidate issue, which indirectly impacts the canvass and proclamation, must be dismissed on jurisdictional grounds. On the issue of Alvin John S. Tañada being a nuisance candidate: Given that Angelina had already been proclaimed and assumed office, any issues concerning the conduct of the canvass and the resulting proclamation, including whether Alvin John S. Tañada is a nuisance candidate, fall under the HRET's exclusive jurisdiction. The Supreme Court is without jurisdiction to resolve the petition for certiorari on this matter.
Main Doctrine
The House of Representatives Electoral Tribunal (HRET) has sole jurisdiction over all contests relating to the election, returns, and qualifications of Members of the House of Representatives once a candidate has been proclaimed, divesting the COMELEC of such jurisdiction.