G.R. No. L-57351 - Festin vs. Faderanga

A petition for disqualification was filed on January 18, 1980 by private respondents with the Commission on Elections (COMELEC) against petitioners running for local elective positions in Banton, Romblon.
The ground for disqualification involved an alleged change of political affiliation from KBL to NP within six months preceding the local election.

Despite the pending disqualification petition, petitioners were declared winners on January 31, 1980 and were proclaimed as duly elected (as mayor, vice mayor, and members of the Sangguniang Bayan).
A telegram from the COMELEC was sent to the Registrar of Banton to suspend the proclamation; however, it was received too late on January 31, 1980.
On February 28, 1980, the petition for disqualification was resolved in favor of petitioners owing to insufficient evidence.
Following this, on March 3, 1980, the Registrar of Banton readvised petitioners, leading to a second proclamation and the taking of oaths of office by petitioners.

A motion for reconsideration was filed by private respondents with the COMELEC on March 19, 1980, and an opposition was later filed by petitioners on April 17, 1980, arguing that no new matters were raised to justify reopening the case.
Despite petitioners contending that the proclamation had achieved finality under the 1978 Election Code, further proceedings and reexaminations ensued, culminating in a reversal of the COMELEC’s earlier stance on December 29, 1980.

On June 26, 1981, this Court rendered a decision in Faderanga v. Commission on Elections, affirming the validity of the proclamation and holding that any contesting of the election results should be pursued via an election protest or a quo warranto proceeding within a prescribed period (15 days from receipt of the decision).
The petitioners had acknowledged receipt of the decision on the same day but instead, later filed a quo warranto petition on July 13, 1981, which was outside the allowed period.
The petitioners attempted to argue that a constitutional violation (in connection with Batas Pambansa Blg. 52 and Presidential Decree No. 1661, as amended) had occurred, despite the existence of a final, binding decision.

Whether the petitioners’ filing of the quo warranto proceeding after the finality of the Faderanga decision undermines the established rules and doctrine regarding election protests and remedies.
Whether the petitioners’ delay in seeking the appropriate remedy (i.e., within the 15-day period following the Faderanga decision) invalidates their petition.

Whether the attempt by petitioners to re-open a matter already decided, using a quo warranto petition as an alternative to an election protest, constitutes an evasive tactic contrary to the binding finality of the initial decision.
Whether the contention alleging constitutional violations is sufficient to overcome the clear directive issued in the prior ruling.

Whether upholding the petitioners’ challenge would disrupt the stability of the official proclamations and the established order of local government offices.
Whether adherence to authoritative rulings, as reaffirmed in several precedents, necessitates dismissal of the petition regardless of the substantive constitutional allegations.