Case Digest (P.E.T. Case No. 001)
Facts:
In P.E.T. Case No. 001, Protestant Miriam Defensor-Santiago filed on July 20, 1992 an election protest against Protestee Fidel V. Ramos, alleging massive fraud and irregularities in the May 11, 1992 presidential election. She designated three pilot areas—Metro Manila, Pampanga, and Zamboanga—comprising 17,527 precincts for ballot revision. By August 16, 1995, revisors had examined ballots in 13,510 precincts, and the Protestant moved to dispense with further revision and deem the process completed. The Tribunal deferred action and required memoranda on whether the protest had become moot following the Protestant’s election as Senator in the May 8, 1995 polls and her assumption of office on June 30, 1995. The Protestant argued that the contest embodied a matter of public interest that survives any change in her political status; the Protestee maintained that the Protestant had ipso facto abandoned her protest by running for and assuming another elective office and urged resolutioCase Digest (P.E.T. Case No. 001)
Facts:
- Parties and Context
- Protestant Miriam Defensor-Santiago filed on July 20, 1992 an election protest against President-elect Fidel V. Ramos, alleging widespread fraud—use of government funds, tampered and substituted ballots, falsified returns and certificates of canvass.
- Ramos was proclaimed winner of the May 11, 1992 presidential election by a narrow margin; the Protestant sought a final determination of the electorate’s true choice.
- Pilot Areas and Revision Process
- The Presidential Electoral Tribunal (PET) designated three pilot areas—Metro Manila, Pampanga, and Zamboanga—comprising 17,527 precincts for initial ballot revision.
- Revisors completed the revision of 13,510 precincts; further progress was delayed by overlapping revision activities in concurrent local election protests (e.g., Makati governor and Pampanga governor contests).
- Motion to Dispense with Remaining Revisions
- On August 16, 1995, Protestant moved to dispense with revision of the remaining 4,017 precincts and to deem the pilot-area revisions complete.
- The PET deferred action and required memoranda on whether the protest had become moot and academic by reason of Santiago’s election and assumption of office as Senator on June 30, 1995.
- Parties’ Contending Positions on Mootness
- Protestant argued that election contests are public-interest proceedings, not susceptible to mootness by assumption of another office; only expiration of the contested term defeats them, and Section 67 of B.P. Blg. 881 (ipso facto resignation) does not apply to non-incumbents.
- Protestee contended that Santiago’s senatorial candidacy and assumption of that office ipso facto abandoned her presidential protest under Dimaporo vs. Mitra, but nonetheless prayed for a merits decision to establish guiding principles in presidential election protests.
Issues:
- Has the presidential election protest become moot and academic by the Protestant’s election and assumption of office as Senator?
- Does the Protestant’s motion to dispense with the remaining pilot-area revisions and her failure to indicate further evidence render the revision findings irrelevant?
- Can the Protestant be deemed to have abandoned or withdrawn her protest by running for and assuming another office during pendency?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)