G.R. No. L-543 - Vera vs. Avelino

The Commission on Elections (COMELEC) submitted a report pursuant to Section 4, Article X of the Constitution, stating that due to acts of terror and violence in the provinces of Pampanga, Nueva Ecija, Bulacan, and Tarlac, the election results in those areas did not reflect the true and free expression of the popular will.
On May 25, 1946, the Philippine Senate convened and proceeded to organize by electing its officers. Subsequently, a resolution (known as the Pendatun Resolution) was adopted stating that petitioners Jose O. Vera, Ramon Diokno, and Jose E. Romero—whose elections were contested—would be deferred from being sworn in or seated pending the resolution of protests against their election based on the report of COMELEC.
The resolution detailed reports of terrorism, ballot secrecy violations, coercion, and intimidation allegedly prevailing in the above provinces, affecting the legitimacy of the election outcomes there.
Petitioners immediately filed this action to annul the Pendatun Resolution, seeking to be allowed to take their seats and exercise their senatorial rights. Respondents opposed, denying the Supreme Court’s jurisdiction and upholding the resolution’s validity.

Previous Philippine jurisprudence, notably *Alejandrino vs. Quezon* (46 Phil. 83), held that courts lack jurisdiction to compel the legislature to perform legislative functions such as seating members, emphasizing the doctrine of separation of powers.
The 1935 Commonwealth Constitution transferred exclusive jurisdiction over election contests ("all contests relating to election, returns, and qualifications") from the legislative chamber to the Electoral Tribunal, which is composed of Supreme Court Justices and members of Congress.
The Senate relied on its inherent power for self-preservation and parliamentary privileges to justify postponing the induction of the petitioners pending the outcome of electoral protests.

Petitioners sought mandamus, injunction, and prohibition to compel respondents to seat them pending resolution of the protests.
Respondents argued based on separation of powers that the Court had no jurisdiction to interfere with the Senate’s internal organization and functions.
The Court proceeded to extensively analyze the jurisdictional issues, the constitutional provisions governing election contests, the separation of powers doctrine, and parliamentary privileges.
There was a division among the Justices between the majority, concurring opinions, and dissents, reflecting profound disagreement over constitutional interpretation and powers of each governmental branch.

Does the Supreme Court have jurisdiction to review and annul the Senate’s Pendatun Resolution deferring the seating of petitioners pending the resolution of electoral protests?
Does the Senate have the constitutional authority to suspend or defer the qualification and seating of members whose elections are contested, independent of the Electoral Tribunal?
Is the Pendatun Resolution a valid exercise of legislative or parliamentary power, or an unconstitutional usurpation of the exclusive jurisdiction of the Electoral Tribunal over election contests?
Can judicial relief by injunction or prohibition be granted to petitioners to restore their seats pending the final determination of the contested elections?
Does the principle of separation of powers preclude judicial interference in the internal affairs of the Senate regarding contested elections?
Is the Pendatun Resolution adopted in a lawful manner, particularly with respect to the existence of quorum and proper procedure?