Case Summary (G.R. No. 24769)
Background of the Election Contest
On June 8, 1925, the municipal board of canvassers in Urdaneta proclaimed the election results, declaring the petitioners as councillors for the term 1925-1928. Disappointed with the outcome, Joaquin Agsalud, a defeated candidate, filed a contest for election in civil case No. 4391 in the Court of First Instance of Pangasinan, naming only the elected candidates as protestees.
Interveners' Motion and Court Proceedings
On June 18, 1925, several other defeated candidates, Agustin Bongolan among them, sought to intervene in the case by filing a motion asserting their interest in the election contest. The legal framework guiding this intervention is outlined in Section 481 of the Election Law, as amended by Act No. 3210, which permits other registered candidates to respond to election contests.
Transfer of Case and Judicial Authority
The case was initially presided over by Judge C. M. Villareal and later transferred to Judge Zandueta due to a procedural rule concerning the assignment of election contests to the same sala. The transfer warranted a reassessment of prior motions, prompting Judge Zandueta to permit the interveners’ motions to stand, which the petitioners sought to contest.
Petition for Writ of Certiorari
The petitioners' primary arguments included the alleged lack of authority of Judge Zandueta to reconsider Judge Villareal’s prior order and the legitimacy of the interveners’ participation in the contest. The petitioners cited precedents asserting that judges in different branches lack the authority to revise orders made by other branches unless a case was pending before them.
Judicial Authority of Judge Zandueta
The court affirmed that after the case was transferred to Judge Zandueta's sala, he retained full authority to act upon the case, including exercising judicial discretion to reconsider prior orders. The transfer negated any suggestion of jurisdictional friction, as Judge Zandueta was properly empowered to address the motions filed before him.
Right of Interveners to Participate
The court further determined that the interveners were within their legal rights to participate in the election contest as articulated in the Election Law. The law allows for all registered cand
...continue readingCase Syllabus (G.R. No. 24769)
Overview of the Case
- The case is an original petition for a writ of certiorari filed by petitioners Federico Eleazar and seven others.
- The petitioners seek relief from an order issued by Judge Francisco Zandueta on August 4, 1925, which admitted respondents Agustin Bongolan and nine others as interveners in an election contest.
- The order required the interveners to post a bond of P500 to cover costs in the proceeding.
Background of the Election Contest
- On June 8, 1925, the municipal board of canvassers of Urdaneta, Pangasinan, proclaimed the election of the petitioners and six others as councillors for the term 1925-1928.
- Joaquin Agsalud, one of the unsuccessful candidates, initiated an election contest on June 12, 1925 (Civil Case No. 4391).
- Agsalud's contest named only the candidates declared elected, in accordance with the Election Law.
Intervention by Defeated Candidates
- On June 18, 1925, defeated candidates Agustin Bongolan and nine associates filed a "Motion of Protest," declaring their candidacy and seeking to be treated as interested parties.
- The Court of First Instance of Pangasinan operates with two branches, presided over by Judges Villareal and Zandueta.
Procedural Developments
- Initially, the contest was presented to Judge Villareal, who later struck the interveners' fi