Morrero v. Bocar
REITERATIONFacts
The Antecedents: Petitioner Gerardo Morrero and respondent Juan L. Bocar were candidates for membership in the National Assembly from the third district of Samar. Respondent Bocar was proclaimed the winner with 5,213 votes as against petitioner Morrero's 4,350 votes. Bocar took his oath of office on November 15, 1935. Procedural History: Petitioner Morrero filed an election protest with the Electoral Commission, alleging that respondent Bocar was ineligible for election as he was not yet thirty years of age at the time of his election and would not attain the required age by the commencement of his term. After due hearing, the Electoral Commission dismissed the protest. The Petition: Petitioner filed a petition with the Supreme Court seeking to review the decision of the Electoral Commission and to prohibit the Auditor General from auditing or authorizing disbursements for Bocar, and to declare Bocar without right to continue holding office.
Issue(s)
Whether the Supreme Court can review the decision of the Electoral Commission regarding the qualifications of a Member of the National Assembly. Whether the Electoral Commission's dismissal of the election protest was subject to judicial interference.
Ruling
The petition is dismissed with costs.
Ratio Decidendi
On the issue of Supreme Court review of Electoral Commission decisions: The Court held that Section 4 of Article VI of the Constitution clearly vests in the Electoral Commission the exclusive jurisdiction to pass upon the qualifications of a Member of the National Assembly. The language of this provision is unambiguous and leaves no room for doubt regarding the Electoral Commission's sole authority in this matter. Therefore, any judgment rendered by the commission in the exercise of this acknowledged power is beyond the interference of the judiciary. The Court emphasized that this exclusivity is a fundamental aspect of the separation of powers and the integrity of the electoral process as established by the Constitution. The intent was to create an independent body to resolve electoral disputes without undue external influence. On the issue of judicial interference with the Electoral Commission's judgment: The Court reiterated that the judgment of the Electoral Commission, rendered after due hearing, is final and beyond the authority of the Supreme Court to review. This finality is predicated on the constitutional grant of exclusive jurisdiction to the Electoral Commission. The only exception, as stated in the cited cases, would be 'upon a clear showing of such arbitrary and improvident use of the power as will constitute a denial of due process of law.' However, the present case did not present such a clear showing of arbitrariness. The decision of the Electoral Commission was based on a hearing, implying that the parties had the opportunity to present their evidence and arguments. Consequently, the Supreme Court could not substitute its own judgment for that of the Electoral Commission.
Main Doctrine
The Electoral Commission is the sole judge of all contests relating to the election, returns, and qualifications of Members of the National Assembly, and its judgment is final and beyond judicial interference, except upon a clear showing of arbitrary and improvident use of power constituting a denial of due process.