G.R. No. 93419-32 - People vs. Delgado

On January 14, 1988, the COMELEC received a report-complaint from Atty. Lauron E. Quilatan, Election Registrar of Toledo City, accusing private respondents of violating the Omnibus Election Code.
The COMELEC directed Atty. Manuel Oyson, Jr., Provincial Election Supervisor of Cebu, to conduct the preliminary investigation in the matter.
Following his investigation, Oyson submitted a report on April 26, 1989, in which he found a prima facie case against each of the private respondents for violations, specifically under Section 261 (y)(2) and (5) of the Omnibus Election Code.

Acting on the findings, the COMELEC en banc, by minute resolutions No. 89-1291 (October 2, 1989) and its amendment No. 89-1574 (November 2, 1989), resolved to file information against the private respondents.
On February 6, 1990, fifteen (15) informations were subsequently filed in the RTC of Toledo City (Criminal Cases Nos. TCS-1220 to TCS-1234).
The COMELEC designated the Regional Election Director of Region VII on three separate occasions to oversee the prosecution, granting him the authority to assign an additional COMELEC prosecutor.

Private respondents, represented by their counsels, filed motions for reconsideration and for the suspension of warrants of arrest on the ground that there was no preliminary investigation.
On February 22, 1990, the RTC issued an order directing the COMELEC—through its Regional Election Director of Region VII—to conduct a reinvestigation of the cases and to submit a corresponding report within ten (10) days after the conclusion of the investigation.
Concurrently, the Toledo City INP was ordered to hold in abeyance the service of the warrants of arrest pending the reinvestigation report.

On March 16, 1990, the COMELEC Prosecutor filed a motion for reconsideration and an opposition to the motion for reinvestigation, contending that review of its decisions is reserved solely for the Supreme Court.
However, the RTC, in an order dated April 5, 1990, denied this contention and upheld its jurisdiction over the matter, thereby confirming its authority to order the reinvestigation.
The petition for certiorari, mandamus, and prohibition was then filed, raising issues regarding the trial court’s authority over the COMELEC, and challenging the notion of judicial review being confined only to the Supreme Court.

The COMELEC’s powers as provided in Section 2, Article IX-C of the Constitution include the enforcement, administration, and decision on various election matters, as well as the power to investigate and prosecute election offenses.
The Omnibus Election Code (Batas Pambansa Blg. 881) reinforces that the COMELEC has the exclusive authority to conduct preliminary investigations of election offenses, while the regional trial courts have exclusive original jurisdiction over the prosecution and trial of these offenses.
Once the COMELEC, through its authorized legal officer, files an information based on a prima facie finding, the RTC acquires jurisdiction over the case, subject to further court orders and oversight, including those relating to reinvestigations and submission of records.

Whether or not the RTC has the power to order the COMELEC—through its Regional Election Director of Region VII or its Law Department—to conduct a reinvestigation of the cases pending before the court.
Whether the trial court’s directive for reinvestigation usurped the functions and authority of the Supreme Court, which is constitutionally the sole body empowered to review the decisions, orders, and resolutions of the COMELEC on certiorari.

Whether the RTC possesses the authority to require the COMELEC Law Department to furnish the records of the preliminary investigation for the purpose of determining probable cause.

Whether the petition, filed in the name of the People of the Philippines, is proper considering that only the Solicitor General is authorized to represent the People in such proceedings.