Facts:

In the case of Macario Arnedo v. The Hon. Julio Llorente and Francisco Liongson, decided on January 9, 1911 (G.R. No. 6313), petitioner Macario Arnedo sought a writ of certiorari against Julio Llorente, the Judge of the Court of First Instance of Pampanga, and Francisco Liongson, the respondent. This situation arose from the general election held on November 2, 1909, to fill the position of provincial governor in Pampanga, where Arnedo and Liongson were rival candidates. The election results revealed that Arnedo received 2,169 votes, while Liongson received 2,995 votes.

Following the election, Arnedo contested the election results in court on various grounds, including allegations of illegally counted votes in favor of Liongson and Liongson's alleged ineligibility due to his prior membership on the Bacolor school board. The Court of First Instance found in favor of Arnedo on March 9, 1910, ruling that he received the majority of the votes and ordered the board of canvassers

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Facts:

The Election and Contest Background

• A general election was held on November 2, 1909, in the Province of Pampanga to fill the office of provincial governor.
• The petitioner, Macario Arnedo, and the respondent, Francisco Liongson, were the opposing candidates in this election.
• The board of canvassers reported that Arnedo received 2,169 votes while Liongson secured 2,995 votes.

Initiation and Proceedings of the Election Contest

• On November 15, 1909, Arnedo instituted the contest before the Court of First Instance of Pampanga.
• The contest was based on allegations including:
• Illegality concerning the counting of a large number of votes cast for Liongson.

ii. The ineligibility of Liongson due to his recent membership in the Bacolor school board until September 30, 1909.

Subsequent Developments and the Vacating Order

• Approximately twenty days after the initial judgment and execution, Liongson’s attorney filed a motion for a “reconsideration and revision” of the judgment with the same court clerk.
• Written arguments were subsequently presented by both parties.
• Counsel for Arnedo contended that the court lacked jurisdiction to entertain the motion for reconsideration.
• On June 29, 1910, the respondent judge vacated his former judgment.
• The new judgment declared that the findings and interpretation of evidence should be altered.
• Consequently, a second mandate was issued to the board of canvassers directing a recanvass of votes.
• Under the new judgment, Liongson was determined to have a majority of 15 votes over Arnedo.

Jurisdictional and Statutory Framework Issues Raised

• The petitioner argued that the trial court exceeded its jurisdiction by vacating a final judgment that had already determined the election contest.
• The issue centered on whether a Court of First Instance, having already issued and executed its mandate, possesses jurisdiction to reopen or revise its final judgment.
• The discussion involved:
• The concept of inherent power to control or revise its own judgments.
• The express statutory provisions under section 145 of the Code of Civil Procedure and section 27 of Act No. 1582.
• The distinction between actions (ordinary suits) and special proceedings such as election contests.

Issue:

• Whether a Court of First Instance, having already rendered and executed a final judgment in an election contest under section 27 of Act No. 1582, has the jurisdiction to reopen or vacate that judgment after the party in favor has acquired the right to execution “as of right.”
• Whether the inherent power of the court extends to setting aside its final judgment, or if such power is strictly limited by statutory provisions, particularly in the context of election contest proceedings.
• Whether section 145 of the Code of Civil Procedure, which grants the power to set aside judgments and grant new trials, is applicable to election contests, given that such proceedings are not defined as “actions” under the Code.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)