Case Digest (G.R. No. 221103) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Regina Ongsiako Reyes v. House of Representatives Electoral Tribunal, G.R. No. 221103, decided on October 16, 2018, petitioner Regina Ongsiako Reyes challenged before the Supreme Court the constitutionality of several provisions of the 2015 Revised Rules of the House of Representatives Electoral Tribunal (2015 HRET Rules). Reyes had two quo warranto cases pending before the HRET—Case No. 13-036 (Noeme Mayores Tan and Jeasseca L. Mapacpac v. Regina Ongsiako Reyes) and Case No. 13-037 (Eric D. Junio v. Regina Ongsiako Reyes). Upon the publication of the 2015 HRET Rules on November 1, 2015, Reyes argued that Rule 6’s requirement of at least one Supreme Court Justice to form a quorum gave the Justices veto power over proceedings, violated the equal protection clause, and unduly favored judicial members over legislators. She also alleged ambiguity in the quorum and voting provisions (Rule 6 in relation to Rule 69) and contended that Rules 15, 17, and 18 unlawfully expanded the Com Case Digest (G.R. No. 221103) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Proceedings
- Petitioner Regina Ongsiako Reyes is respondent in two quo warranto cases before the House of Representatives Electoral Tribunal (HRET): Case No. 13-036 (Tan and Mapacpac v. Reyes) and Case No. 13-037 (Junio v. Reyes).
- On November 1, 2015, HRET promulgated its 2015 Revised Rules.
- Petitioner’s Contentions
- Rule 6(a) of the 2015 HRET Rules requires at least one Supreme Court Justice plus four other tribunal members to constitute a quorum, allegedly granting the Justices veto power and privileging them over six legislator-members.
- Quorum provisions are ambiguous, allowing inhibited members to count and potentially reducing effective votes to one.
- Rules 15, 17, and 18 expand COMELEC’s jurisdiction by making “valid proclamation,” “proper oath,” and “assumption of office” requisites for membership and altering protest filing deadlines.
- HRET’s Defense
- HRET has constitutional authority to promulgate its procedural rules.
- Quorum rule reflects the constitutional composition difference (3 Justices vs. 6 legislators) and ensures judicial participation.
- Membership requisites and filing periods are within HRET’s power and promote orderly determination of contests.
Issues:
- Does Rule 6(a) of the 2015 HRET Rules—requiring at least one Justice to constitute a quorum—violate equal protection or upset the constitutional balance between judicial and legislative members?
- Is Rule 6 ambiguous in relation to Rule 69, particularly on counting inhibited or disqualified members for quorum and voting purposes?
- Do Rule 15(2), when read with Rules 17 and 18, unlawfully expand COMELEC’s jurisdiction or create indeterminate deadlines by conditioning membership on proclamation, oath, and assumption of office?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)