Title
Marquez vs. Commission on Elections
Case
G.R. No. 127318
Decision Date
Aug 25, 1999
Post-1996 SK election, Marquez’s eligibility challenged; MeTC jurisdiction upheld for post-proclamation disqualification under OEC Section 253, not COMELEC Resolution 2824.

Case Digest (G.R. No. 148560)

Facts:

  • Background of the SK Elections
    • The elections were held on May 6, 1996, for the Sangguniang Kabataan (SK) positions in Barangay Putatan, Muntinlupa City.
    • Francis King L. Marquez and Liberty Santos were among the candidates; Marquez garnered the highest number of votes and was proclaimed SK Chairman on election day.
  • Filing of the Election Protest
    • On May 16, 1996, Liberty Santos, then a protestant, filed an election protest before the Metropolitan Trial Court (MeTC), Branch 80, challenging Marquez’s election on the ground of disqualification by age.
    • The protest was docketed as Civil Case No. SP 3255 and alleged that Marquez did not meet the age qualification for the office.
  • Initial Court Actions and Motion to Dismiss
    • In an order dated May 24, 1996, the trial court found the protest sufficient and issued a Temporary Restraining Order (TRO) preventing Marquez from taking his oath of office.
    • On May 27, 1996, petitioner Marquez filed a Motion to Dismiss the election protest, arguing that:
      • The averments in the protest exclusively concern his eligibility or qualification, essentially converting it into a quo warranto proceeding rather than a conventional election protest.
      • The trial court lacks jurisdiction over matters filed after the election and subsequent proclamation.
      • There was alleged non-compliance with Supreme Court Administrative Circular No. 04-94 by the election officer, whose inaction allegedly triggered the protest.
  • Substantive Arguments and Statutory Issues Raised
    • Petitioner’s Argument:
      • Marquez contended that the relevant provision is Section 6 of COMELEC Resolution No. 2824, which confines the determination of candidate eligibility or qualification to the city/municipal Election Officer prior to the elections.
      • He asserted that cases filed after the election, such as his own, fall outside the scope of the said resolution and should be dismissed as lacking jurisdiction of the trial court.
    • Respondent’s Argument:
      • Liberty Santos argued for a broad interpretation of “election protest” to encompass all issues arising from the election, including challenges to the eligibility or qualification of a candidate post-proclamation.
      • She maintained that the inaction of the election officer rendered the filing proper and that there was no pending administrative petition on the same issue.
  • The Applicable Legal Provisions and Jurisprudence
    • COMELEC Resolution No. 2824:
      • Section 6 states that eligibility or qualification disputes of SK candidates filed prior to the elections are decided by the city/municipal Election Officer, whose decision is final.
      • Section 49 mandates that the proclamation of winning candidates is final but asserts that the Metropolitan/Municipal/Municipal Circuit Trial Courts (MeTC/MTC/MCTC) have original jurisdiction over election protest cases filed after the proclamation.
    • Omnibus Election Code (OEC) and R.A. 7808:
      • Section 253 of the OEC provides for petition for quo warranto filed by any voter contesting the election of any officer on the ground of ineligibility, to be filed within ten days after the proclamation.
      • R.A. 7808 extended the governing law of the OEC to the SK elections, thereby incorporating the provisions of Sections 252 and 253 of the OEC.
    • Jurisprudential Precedent:
      • The earlier Mercado doctrine, which had the Board of Election Supervisors decide SK election protests under COMELEC Resolution No. 2499, was referenced but is no longer controlling following the transfer of jurisdiction to the trial courts by Resolution No. 2824.
      • Subsequent case law emphasized that disputes involving the election of SK officials post-proclamation are to be handled as quo warranto proceedings.
  • COMELEC Resolution and its Consequences
    • The Commission on Elections, en banc, upheld the jurisdiction of the Metropolitan Trial Court to hear and decide the disqualification case as a quo warranto proceeding under Section 253 of the Omnibus Election Code.
    • It was determined that:
      • The election protest, although involving a challenge to candidate eligibility, was filed after the election and proclamation, thereby invoking the trial court’s jurisdiction.
      • Section 6 of COMELEC Resolution No. 2824 applies pre-election and does not bar the quo warranto proceeding post-election.
  • Final Disposition in the Lower Courts
    • The trial court interpreted Section 6 of Resolution No. 2824 as referring exclusively to pre-election eligibility disputes, while post-election disqualification cases fall under Section 253 of the OEC.
    • Based on this interpretation and the timely filing of the protest within the reglementary period, the Metropolitan Trial Court maintained original jurisdiction over the case filed by Liberty Santos.

Issues:

  • Jurisdictional Authority
    • Whether the Metropolitan Trial Court, Branch 80, Muntinlupa City, has the jurisdiction to entertain a disqualification case (quo warranto proceeding) filed after the proclamation of the SK election results, despite the existence of Section 6 in COMELEC Resolution No. 2824.
  • Applicability of Statutory Provisions
    • Whether Section 6 of COMELEC Resolution No. 2824, which confines eligibility disputes to the election officer, should control, or if the post-election disqualification challenge falls under Section 253 of the Omnibus Election Code as part of a quo warranto proceeding.
    • The determination of whether similar disputes involving the election qualification of a candidate should be heard by election officers or trial courts.
  • Interpretation of “Election Protest” and the Scope of Relief
    • Whether the term “election protest” should be narrowly construed to only address anomalies in the conduct of the elections or broadly interpreted to include disqualification challenges such as quo warranto suits.
    • Whether the filing of the protest by Liberty Santos satisfies the requirements under the applicable rules and administrative circulars.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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