Case Digest (G.R. No. 144090)
Facts:
Antonio Gallardo, Antonio Arevalo, Cresencio Echaves, Emmanuel Aranas, Palermo Sia, Ronnie Rambuyon, Primo Navarro, and Noel Navarro v. Hon. Sinforoso V. Tabamo, Jr., G.R. No. 104848, January 29, 1993, Supreme Court En Banc, Davide Jr., J., writing for the Court. Petitioners are provincial officials and employees of Camiguin (Gallardo was Governor and a reelection candidate; Arevalo, Echaves, Aranas and Sia were provincial officers; Rambuyon, Primo and Noel Navarro were project laborers). Respondent judge is the Presiding Judge of Branch 28, RTC Mambajao, Camiguin. The private respondent in the proceeding below was Pedro P. Romualdo, Jr., then incumbent Congressman and candidate for the same congressional seat.On 10 April 1992 Romualdo filed Special Civil Action No. 465 in Branch 28, RTC, seeking injunction, prohibition and mandamus to restrain petitioners from pursuing or disbursing funds for a number of “Locally-Funded” and “Foreign-Assisted” public works projects; he alleged these acts violated paragraphs (a), (b), (v) and (w) of Section 261 of the Omnibus Election Code (Batas Pambansa Blg. 881) and COMELEC Resolution No. 2332 (fixing the 45-day ban). Romualdo framed the relief both as protection of his candidacy (alleging voter corruption by hiring project laborers) and as a taxpayers’ suit alleging waste of public funds.
The trial court (Branch 28, RTC) issued a Temporary Restraining Order (TRO) on 10 April 1992 enjoining the respondents from prosecuting the listed projects, disbursing funds, or issuing treasury warrants for them, and set hearing on a preliminary injunction for 24 April 1992. Instead of answering, petitioners filed this Rule 65 special civil action for certiorari and prohibition in the Supreme Court, asserting the RTC lacked jurisdiction because the matter involved enforcement of the Omnibus Election Code — a province, they argued, exclusively within the Commission on Elections (COMELEC). They also alleged lack of real party-in-interest, failure to exhaust administrative remedies, and bias by the trial judge.
The Supreme Court issued an interim TRO on 20 April 1992 directing the respondent j...(Subscriber-Only)
Issues:
- Does the Regional Trial Court have jurisdiction over Special Civil Action No. 465 which seeks to enjoin activities alleged to violate the Omnibus Election Code?
- Is the RTC’s jurisdiction under the election laws limited to criminal actions for violations of the Omnibus Election Code?
- Does the private respondent (Romualdo) have legal standing to file the complaint and is his remedy improper for failure...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)