Roxas v. Binay
REITERATIONFacts
The Antecedents: Following the May 10, 2010 National and Local Elections, Congress, sitting as the National Board of Canvassers (NBOC), proclaimed protestee Jejomar C. Binay as the duly elected Vice President, who garnered 14,645,574 votes, with protestant Manuel A. Roxas receiving 13,918,490 votes, a margin of 727,084 votes. Procedural History: On July 9, 2010, protestant Roxas initiated a protest before the Presidential Electoral Tribunal (PET), praying for various reliefs including a Precautionary Protection Order (PPO), the creation of a Technical Panel for a comprehensive forensic analysis of the Automated Election System, the conduct of a Random Manual Audit, a manual revision of votes, the annulment of Binay's proclamation, and Roxas's proclamation as the duly elected Vice President. Protestee Binay filed an Answer with Motion for Preliminary Hearing on Affirmative Defenses and Counter-Protest, asserting the Tribunal's lack of jurisdiction and alleging fraud, anomalies, and irregularities in specific regions that favored Roxas. The PET issued a PPO on August 31, 2010, covering all 76,340 clustered precincts. Subsequent preliminary conferences were held, and various motions were filed by the parties and the Commission on Elections (COMELEC). The PET granted COMELEC's request to conduct the mandatory Hardware Acceptance Test (HAT) for PCOS Machines for the 2013 elections, which necessitated the retrieval of ballot boxes. The PET later directed the parties to move in the premises regarding their interest in pursuing the case, especially after they filed certificates of candidacy for the Presidency in the May 9, 2016 elections. On February 23, 2016, the PET lifted the PPO in response to COMELEC's request, in view of the upcoming May 9, 2016 elections. The Petition: The case originated from a protest filed by Manuel A. Roxas against the proclamation of Jejomar C. Binay as Vice President in the 2010 elections. Roxas sought to annul Binay's proclamation and be declared the winner, alleging issues with the automated election system and requesting forensic analysis and manual audits. Binay, in turn, filed a counter-protest, alleging fraud and irregularities that favored Roxas in certain regions, and sought the dismissal of Roxas's protest.
Issue(s)
Whether the Presidential Electoral Tribunal should proceed with resolving the protest and counter-protest despite the expiration of the term of office for the contested Vice Presidency and the assumption of office by a new Vice President elected in a subsequent election. Whether the protest and counter-protest have become moot and academic.
Ruling
The Presidential Electoral Tribunal dismissed the protest filed by Manuel A. Roxas and the counter-protest filed by Jejomar C. Binay on the ground of mootness. The Tribunal held that any decision rendered would have no practical or useful purpose and could not be enforced, rendering further proceedings an exercise in futility.
Ratio Decidendi
On Whether the Presidential Electoral Tribunal should proceed with resolving the protest and counter-protest despite the expiration of the term of office for the contested Vice Presidency and the assumption of office by a new Vice President elected in a subsequent election: The Tribunal ruled that it should not proceed with the case. The term of office of the Vice President contested in the 2010 elections had expired at noon on June 30, 2016. Furthermore, a new set of national and local officials had been elected in the May 9, 2016 elections, with Rodrigo R. Duterte proclaimed President and Ma. Leonor G. Robredo proclaimed Vice President, both of whom had taken their oaths of office and assumed their positions. Consequently, any decision by the Tribunal on who won the 2010 Vice Presidential election would have no practical or useful purpose and could not be enforced. The Tribunal cited established jurisprudence, such as Baldo, Jr. v. Commission on Elections and Sales v. Commission on Elections, which hold that courts should not pass upon issues that have become moot and academic. On Whether the protest and counter-protest have become moot and academic: The Tribunal concluded that both the protest and the counter-protest had indeed become moot and academic. The expiration of the term of office for which the election was being contested, coupled with the assumption of office by a new Vice President, rendered the resolution of the case moot. The Tribunal reiterated the settled rule that it should not proceed in a case where any decision would have no practical or useful purpose and cannot be enforced. Therefore, continuing the proceedings would be an exercise in futility, as there was no longer any practical reason to determine the winner of the 2010 Vice Presidential elections when that term had already concluded.
Main Doctrine
The Presidential Electoral Tribunal (PET) dismissed both the protest and counter-protest filed in relation to the 2010 Vice Presidential elections on the ground of mootness. This dismissal was based on the fact that the term of office for which the election was being contested had already expired, and a new Vice President had been elected, proclaimed, and had taken her oath of office. The Tribunal reiterated the established legal principle that courts should not proceed with cases that have become moot and academic, as any decision rendered would have no practical or useful purpose and could not be enforced, thus making further proceedings an exercise in futility.