G.R. No. 132986 - Enrile vs. Senate Electoral Tribunal

On January 20, 1995, Senator Aquilino Pimentel, the private respondent, filed an election protest with the Senate Electoral Tribunal (SET) against Senator Juan Ponce Enrile, the petitioner, and other senatorial candidates who emerged winners in the May 1995 elections (SET Case No. 001-95).
On June 30, 1995, petitioner Enrile filed his answer along with a counter-protest in response to Pimentel’s protest.

The SET ordered the submission of a list of pilot precincts, which were to comprise not more than 25% of the precincts involved in the protest.
The SET conducted a meticulous revision of ballots in the designated pilot precincts located in various municipalities and provinces (e.g., Paoay in Ilocos Norte, Tarlac, Tawi-Tawi, Maguindanao, Sulu, Bulacan, Lanao del Sur, Lanao del Norte, Pasig City, BiAan, Laguna, Cuyapo, Nueva Ecija, Pangasinan, Agusan del Sur and Agusan del Norte).
Parties were directed by the SET to submit evidence and respective memoranda in relation to the protest.

On August 21, 1997, the SET, without final resolution of the election protest, held a press conference at the Supreme Court Session Hall and released the partial results based on the revision of ballots in the pilot precincts.
A press release titled “Partial Results in Pimentel’s Protest” was issued showing a tabulation where petitioner Enrile’s ranking fell from number 11 to number 15.
Subsequent to the press conference, petitioner Enrile filed a motion on September 24, 1997, to set aside the partial results and request another appreciation of ballots in the presence of all parties, alleging that the published results were manifestly erroneous.

The SET acknowledged an “oversight” in its counting—specifically, an error in the tally of votes from Paoay, Ilocos Norte, where 30,000 votes had been erroneously deducted from petitioner Enrile’s total.
The error was corrected by reintegrating the 30,000 votes into Enrile’s tally, with a similar adjustment made for another candidate, Mitra (20,000 votes added back).
Despite the corrections, the SET maintained that there was no sufficient basis to annul its partial tabulation, as the overall ranking of candidates was not affected.
The SET denied petitioner’s motion for both setting aside the partial results and for his motion for reconsideration (Resolution No. 98-02).

The alleged grave abuse of discretion amounting to lack or excess of jurisdiction in denying the motion to annul the erroneous partial tabulation.
The alleged patent and gross errors in recalculating the vote counts using various election documents.
The issuance of “partial and tentative” results by the SET, which petitioner claimed caused him grave prejudice.
The decision denying his entitlement to be heard in the appreciation of ballots.

Respondents, including Senator Pimentel and the Solicitor General, maintained that the SET’s actions were proper and that the petition was moot due to the expiration of the contested senatorial term on June 30, 1998.

Whether the Senate Electoral Tribunal committed grave abuse of discretion by:

Denying petitioner Enrile’s motion to set aside the partial results of the ballot revision.
Declining to allow Enrile’s participation in the subsequent appreciation of ballots.

Whether the alleged errors in the vote tally (specifically, the discrepancies noted in the Paoay, Ilocos Norte precinct) provided sufficient basis for annulling the partial tabulation.
Whether the petition is justiciable given the fact that the contested senatorial seat had already expired, rendering the issues moot and academic.
Whether the actions of the SET, including its process in reconciling various election documents and the adjustment of votes, amounted to an encroachment on judicial functions.