Case Digest (G.R. No. 188308) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Joselito R. Mendoza v. Commission on Elections and Roberto M. Pagdanganan (G.R. No. 188308, October 15, 2009), the petitioner, Joselito R. Mendoza, was proclaimed Governor of Bulacan following the May 14, 2007 elections. The respondent, former Governor Roberto M. Pagdanganan, filed an election protest with the Commission on Elections (COMELEC), docketed as EPC No. 2007-44 before its Second Division. After the revision of ballots in numerous precincts and the presentation of evidence, both parties submitted their memoranda and the case was deemed submitted for resolution. On March 2, 2009, upon transfer of all provincial ballot boxes to the Senate Electoral Tribunal (SET) for a separate senatorial contest, Mendoza moved to suspend the COMELEC proceedings; the Second Division denied his motion by orders dated April 29 and May 26, 2009. Alarmed by reports of COMELEC “proceedings” within the SET premises without his knowledge, Mendoza’s counsel wrote SET Secretary Irene Guevarra, Case Digest (G.R. No. 188308) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Contest Background
- May 14, 2007 elections for Bulacan Governor: Mendoza proclaimed winner; Pagdanganan filed protest EPC No. 2007-44.
- COMELEC Second Division conducted ballot revision in Intramuros; parties presented evidence, filed memoranda, and case was submitted for decision.
- Transfer and COMELEC’s Actions
- March 2, 2009: COMELEC transferred Bulacan ballot boxes to the Senate Electoral Tribunal (SET) for a separate senatorial protest (Pimentel vs. Zubiri).
- Petitioner moved to suspend proceedings; COMELEC Second Division denied the motions on April 29 and May 26, 2009.
- June 10–17, 2009: Petitioner’s counsel inquired with SET Secretary; SET authorized COMELEC to “conduct proceedings” at SET under COMELEC Resolution No. 2812 (1995) coordinating ballot revisions.
- Petitioner filed certiorari petition against COMELEC’s actions, alleging due process violations and excess of jurisdiction.
Issues:
- Due Process
- Did COMELEC violate petitioner’s due process by conducting proceedings at SET premises without notice or participation?
- Jurisdiction and Discretion
- Did COMELEC gravely abuse its discretion—or act beyond jurisdiction—by appreciating ballots no longer in its official custody and outside its premises?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)