G.R. No. 161651 - Lateo y Eleazar vs. People

Atty. Romulo B. Macalintal filed an undesignated petition before the Supreme Court en banc, challenging the constitutionality of the Presidential Electoral Tribunal (PET) under Section 4, Article VII of the 1987 Constitution.
He contended that the PET, with its own budget, seal, staff, and nomenclature (Chairman and Members), exceeded the Court’s authority to “promulgate rules” and infringed the prohibition in Section 12, Article VIII against designating justices to quasi-judicial bodies.

Rule 3—designates the Chief Justice and Associate Justices as Chairman and Members of the PET.
Rule 8(e)—authorizes appointment of personnel and confidential employees.
Rule 9—creates an “Administrative Staff of the Tribunal” with Clerk and Deputy Clerk.
Rule 11—provides a distinct seal for the PET.

Petitioner relied on Buac v. COMELEC’s statement that the PET exercises “quasi-judicial power” and argued this ran afoul of Section 12, Article VIII.

The Office of the Solicitor General (OSG) filed a Comment highlighting the petition’s unspecified basis and raising issues of standing and merits.
The OSG framed three issues: (a) petitioner’s locus standi; (b) constitutionality of PET creation; (c) constitutionality of designating Supreme Court justices.
In his Reply, petitioner maintained his standing as citizen, taxpayer, and lawyer, and reiterated his substantive objections.
The Court consolidated and narrowed the questions, first resolving standing before reaching substantive issues.

Whether petitioner has locus standi to challenge the constitutionality of the PET.
Whether the creation of the PET violates Section 4, Article VII of the 1987 Constitution.
Whether designating Supreme Court justices as members of the PET contravenes Section 12, Article VIII of the Constitution.