G.R. No. L-1678 - People vs. Cana

Petitioner: Carmelo F. Lazatin, who was proclaimed, took his oath, assumed office, and began discharging his duties as Congressman of the First District of Pampanga.
Respondents:

Legal Issue: Petition filed by Lazatin challenging the jurisdiction of COMELEC in annulling his proclamation, asserting that the House Electoral Tribunal is the sole judge for election contests (Sec. 17, Art. 6, 1987 Constitution).

The petitioner was proclaimed winner through a COMELEC Resolution issued via a Telex Order that directed the canvassing board to proclaim the winner under Section 245 of the Omnibus Election Code.
Despite allegations of irregularities concerning the election returns in Pampanga, the proclamation had already been finalized.

Candidates Buan, Jr. and Timbol argued that the petition had become moot and academic, as the COMELEC Resolution was final and executory when a temporary restraining order was issued on October 6, 1987.
They contended that the COMELEC hastily proclaimed Lazatin without first settling their separate written protests (referenced as SPC Nos. 87-234, 87-358, 87-351).
A separate protest by the COMELEC alleged that the proclamation was illegal and void, contending that the canvassing board corrected contested returns prematurely before resolving pending protests.

The Solicitor General submitted a comment asserting that the petition should be entertained because the valid proclamation was proper under the law.
Petitioner’s Consolidated Reply: Reiterated earlier arguments reinforcing his claim and contesting the validity of the COMELEC’s actions.

On November 17, 1987, the Supreme Court resolved to give due course to the petition, emphasizing the merit of the petition based on the petitioner’s status as duly proclaimed, sworn-in, and functioning Congressman.

Once proclaimed and having assumed office, challenging the proclamation by the COMELEC would amount to an encroachment on the exclusive jurisdiction of the House Electoral Tribunal in handling electoral protests.

Asserted that its resolution to proclaim Lazatin was based on authoritative compliance with Section 245 of the Omnibus Election Code.
Maintained that the corrections made to the returns did not warrant an immediate confrontation with the ongoing protests and that such matters are best adjudicated by the Electoral Tribunal.

Whether the COMELEC was entitled to annul the proclamation after the petitioner had already taken his oath of office and assumed his congressional duties.
Whether the House Electoral Tribunal, not the COMELEC, should be the sole adjudicator of election contests as mandated by Sec. 17, Art. 6 of the 1987 Constitution.

Whether the petition should be considered moot and academic given that the COMELEC’s Resolution had become final and executory.
The impact of the temporary restraining order issued on October 6, 1987, on the viability of the petition.

Whether the Telex Order by which the COMELEC granted the canvassing board the authority to proclaim the winner under Section 245 of the Omnibus Election Code was legally valid.
The propriety of the COMELEC’s action in proclaiming petitioner Lazatin despite the existence of pending protests from rival candidates.