Case Digest (G.R. No. L-12596)
Facts:
In Jose L. Guevara v. Commission on Elections (G.R. No. L-12596, July 31, 1958), petitioner Jose L. Guevara, publisher of the *Sunday Times*, was summoned by the Commission on Elections (COMELEC) to show cause for contempt after he authored an article entitled “Ballot Boxes Contract Hit,” published June 2, 1957. The piece alleged improprieties in COMELEC’s award of contracts for 34,000 ballot boxes to three steel manufacturers—National Shipyards & Steel Corporation (NASSCO), Acme Steel Mfg. Co., Inc. (ACME), and Asiatic Steel Mfg. Co., Inc.—and tended to influence its pending third petition for reconsideration filed May 20 and supplemented June 1, 1957. The controversy arose when ACME failed to sign its contract within the prescribed period, prompting COMELEC on May 13 to reallocate its 11,000‐box allotment equally between NASSCO and Asiatic and to conduct formal hearings on ACME’s successive motions for reconsideration. After denying ACME’s third motion on June 4, COMELEC issueCase Digest (G.R. No. L-12596)
Facts:
- Award and execution of contracts for ballot boxes
- On May 4, 1957, the Commission on Elections (COMELEC) awarded contracts for 34,000 ballot boxes as follows:
- National Shipyards & Steel Corporation (NASSCO): 12,000 boxes at ₱17.64 each
- Acme Steel Mfg. Co., Inc. (ACME): 11,000 boxes at ₱14.00 each
- Asiatic Steel Mfg. Co., Inc. (ASIATIC): 11,000 boxes at ₱17.00 each
- On May 8, 1957, NASSCO and ASIATIC signed their contracts. On May 13, 1957, COMELEC cancelled ACME’s award for failure to sign and reallocated its 11,000 boxes equally between NASSCO and ASIATIC, contracts signed May 16, 1957.
- Reconsideration petitions by ACME
- First petition (May 14, 1957) – denied May 16, 1957
- Second petition (May 16, 1957) – denied May 17, 1957
- Third petition (May 20, 1957) – prompted formal investigation; hearings on May 24; ACME memorandum filed May 28; resolution denying third motion issued June 4, 1957
- Contempt proceedings against petitioner
- June 2, 1957: Petitioner José L. Guevara published an article entitled “Ballot Boxes Contract Hit” in the Sunday Times, alleging interference, fraud, and undermining of COMELEC’s functions
- COMELEC ordered petitioner to show cause why he should not be punished for contempt for publishing an article allegedly tending to influence a pending COMELEC adjudication and degrade its members
- Petitioner filed a motion to quash on grounds of lack of jurisdiction, administrative vs. judicial function, mootness of controversy, and fair-report privilege
- COMELEC denied the motion to quash but allowed fifteen days to elevate the jurisdictional issue to the Supreme Court; petitioner filed the present petition for prohibition with preliminary injunction
Issues:
- Jurisdictional question under Republic Act No. 180, Section 5
- Whether COMELEC may punish contempts under Rule 64 of the Rules of Court by virtue of R.A. 180, §5
- Whether such power extends to publications alleged to influence COMELEC’s proceedings
- Nature of COMELEC’s function in awarding ballot‐box contracts
- Whether the purchase of ballot boxes is a ministerial (administrative) duty or a quasi‐judicial function
- Whether contempt power may be exercised in furtherance of purely administrative acts
- Constitutionality and scope of COMELEC’s contempt jurisdiction
- Whether Section 5 of R.A. 180 unconstitutionally confers judicial contempt power on an administrative body
- Whether COMELEC properly exercised or exceeded its authority in the instant case
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)