Ello v. Valdevin
REITERATIONFacts
The Antecedents: This case concerns a municipal election contest for the office of municipal president of Patanongan, Province of Antique, between Anselmo Ello and Inocencio Valdevin. The core of the dispute revolves around the adjudication of votes, specifically concerning ballots with detachable coupon numbers that were allegedly not properly handled by the election officials. Procedural History: The matter originated as an election contest decided by the respondent Judge of First Instance of Antique. Following the judge's decision, which awarded 291 votes to Valdevin and 289 to Ello, the petitioner, Anselmo Ello, sought relief from this Court. The respondent judge's decision was challenged due to the alleged failure to adjudicate certain ballots, which the petitioner claimed constituted an excess of jurisdiction. The Petition: The petitioner, Anselmo Ello, filed a petition for certiorari with this Court, seeking the annulment or modification of the respondent judge's order. The petition asserts that the respondent judge exceeded his jurisdiction by failing to adjudicate three ballots with detachable coupon numbers in favor of respondent Valdevin and six such ballots in favor of petitioner Ello. The respondents filed a demurrer, arguing that the facts alleged do not constitute a cause of action for certiorari, a defense that the Court treated as an answer for the purposes of its ruling.
Issue(s)
Whether the respondent judge's failure to adjudicate certain ballots with detachable coupon numbers in an election contest constitutes an excess of jurisdiction remediable by certiorari.
Ruling
The petition for certiorari is denied. The Supreme Court held that the respondent judge's actions, even if erroneous, were committed within the exercise of his jurisdiction, and therefore, certiorari is not the proper remedy.
Ratio Decidendi
On Issue 1: The Supreme Court held that the respondent judge's failure to adjudicate nine ballots with detachable coupon numbers did not constitute an excess of jurisdiction. The Court reiterated the well-settled doctrine that certiorari is an extraordinary remedy available only when a lower court or tribunal has acted without or in excess of its jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction. The Court emphasized that errors of fact or law, even if erroneous, committed by a court while acting within its lawful jurisdiction are not subject to correction through certiorari. The Court cited numerous previous decisions, including Leung Ben vs. O'Brien, Bustos vs. Moir and Fajardo, De la Cruz vs. Moir, Venturanza vs. Court of First Instance of Batangas and Cabrera, and Guerrero vs. Villareal and Guerrero, to support the principle that an error committed in the exercise of jurisdiction does not divest the court of that jurisdiction. Therefore, the petitioner's claim of excess of jurisdiction was unfounded, and the petition for certiorari was denied.
Main Doctrine
The Supreme Court reiterated that the writ of certiorari is an extraordinary remedy available only when a lower court or tribunal has acted without or in excess of its jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction. Errors of fact or law, even if erroneous, committed by a court while acting within its lawful jurisdiction are not subject to correction through certiorari. The Court emphasized the distinction between jurisdiction and the exercise of jurisdiction, stating that an error committed in the exercise of jurisdiction does not divest the court of that jurisdiction.