Case Summary (G.R. No. L-27360)
Facts of the Election Contest
In the 1987 elections, Pineda received 31,700 votes and Bondoc 28,400. Bondoc filed an electoral protest with the HRET, composed of three Supreme Court Justices and six House members chosen on a proportional‐representation basis. After ballot revision and a re‐count, the HRET majority (5–4) determined that Bondoc led by 107 votes. Congressman Camasura cast a decisive vote for Bondoc, later disclosing it to LDP leadership. Fearing an adverse HRET ruling, the LDP expelled Camasura on grounds of “party disloyalty.” The House then voted to withdraw and rescind his HRET nomination. Without Camasura’s vote, the HRET cancelled the planned promulgation of its decision in Bondoc’s favor.
Constitutional Foundation of the HRET
Article VI, Section 17 of the 1987 Constitution establishes the Senate and House Electoral Tribunals as the “sole judge” of contests concerning election, returns, and qualifications of their members. Each tribunal’s nine‐member composition—three Supreme Court Justices designated by the Chief Justice and six legislators chosen on a proportional‐representation basis—reflects a balance between judicial expertise and political representation. The “sole judge” language underscores the exclusive jurisdiction and independence of the tribunals from both legislative and judicial encroachment.
Independence and Impartiality of the Tribunal
The framers intended the HRET to function as an impartial, quasi‐judicial body within a political environment. Although two‐thirds of its members are legislators, they must serve not as party representatives but as neutral adjudicators once seated. Disloyalty to party or breach of political discipline cannot justify removal from the tribunal, since such grounds threaten its independence and undermine public confidence in electoral justice.
Invalidity of the House’s Resolution
The House’s action to rescind Camasura’s nomination for “party disloyalty” constituted a grave abuse of discretion for two reasons:
- It interfered with the exclusive jurisdiction of the HRET, effectively manipulating its composition to frustrate a decision duly reached through ballot examination and judicial deliberation.
- It violated Camasura’s security of tenure as a tribunal member, which mirrors the constitutional protection afforded to the judiciary and may be terminated only for valid legal cause (e.g., death, disability, formal change of party affiliation), none of which existed here.
Security of Tenure for Tribunal Members
Membership in the HRET is coextensive with the legislative term and cannot be curtailed at will. Removal for “party disloyalty,” absent formal re‐registration in another party, fails to m
Case Syllabus (G.R. No. L-27360)
Facts of the Case
- In the May 11, 1987 elections for Pampanga’s Fourth District, Marciano M. Pineda (LDP) garnered 31,700 votes and Emigdio A. Bondoc (NP) 28,400, a 3,300‐vote margin.
- Pineda was proclaimed winner on May 19, 1987; Bondoc filed HRET Case No. 25 contesting the result.
- The HRET comprised nine members: three Supreme Court Justices (Herrera, Cruz, Feliciano) and six Congressmen chosen by proportional representation (four LDP, one NP, one GAD/NP).
- After hearings, a majority decision in October 1990 found Bondoc won by 23 votes; LDP members requested a further ballot reappreciation.
- Recount raised Bondoc’s lead to 107 votes; Congressmen Camasura (LDP) and Cerilles (NP) joined the Justices in voting for Bondoc.
- On March 4, 1991, Camasura disclosed to LDP Secretary-General Cojuangco that he voted “with truth and justice” and would honor the tribunal’s result.
Procedural History
- March 5, 1991: HRET issued notice to promulgate Bondoc decision on March 14.
- March 13, 1991: LDP Davao del Sur Chapter expelled Camasura for alleged disloyalty; LDP Executive Committee confirmed expulsion.
- The House, in plenary session, withdrew Camasura’s nomination to the HRET and rescinded his election as member.
- March 14, 1991: HRET Resolution No. 91-0018 cancelled promulgation for lack of a five‐member concurrence.
- March 19, 1991: Supreme Court directed Justices Herrera, Cruz, Feliciano to resume HRET duties, reaffirming members sit as impartial judges and enjoy security of tenure.
- March 21, 1991: Bondoc filed a petition for certiorari, prohibition, and mandamus to annul the House resolution, reinstate Camasura, and prohibit his replacement.
Issues Presented
- May the House, at the behest of its dominant party, alter its