Case Summary (G.R. No. 182374)
Election Protest and Initial Rulings
Following the proclamation of Reynaldo Teh Bitong as the duly-elected mayor with a margin of 48 votes over Jeremias V. Esteves, the latter filed an election protest (EPC No. 99) before the Regional Trial Court (RTC) Branch 96 in Baler, Aurora, on May 25, 2007. The RTC issued a precautionary protection order to secure the integrity of the ballots and election materials. The private respondent's subsequent answer was admitted, and the RTC created revision committees to address the protest.
COMELEC Involvement and Hearings
On September 6, 2007, the private respondent sought to dismiss the election protest on procedural grounds, alleging defects in form and substance due to the lack of specific precincts noted for alleged fraudulent activity. The RTC denied this motion on September 8, prompting the private respondent to seek relief from the COMELEC, which issued a temporary restraining order (TRO) against the RTC's proceedings on December 6, 2007. In the interim, the petitioner filed a separate civil action challenging the COMELEC's intervention, which was later dismissed for insufficient grounds.
COMELEC’s Final Resolution and Dissent
On February 29, 2008, the COMELEC issued a resolution, later contested in this proceeding, which nullified the RTC's order and dismissed the election protest. A dissenting opinion was recorded by Commissioner Rene V. Sarmiento, highlighting the internal division within the COMELEC regarding the handling of this election case.
Legal Challenges Presented by the Petitioner
The petitioner’s main arguments in seeking judicial review included the assertion that the COMELEC acted without jurisdiction in this context and failed to meet constitutional requirements, as the resolution was not reached by a majority vote of its members. He also contended that the dismissal violated the intent of A.M. No. 07-4-15-SC, which governs electoral protests.
Jurisdictional and Procedural Deficiencies
In evaluating the jurisdiction, the Court referenced Section 3, Article IX-C and Section 7, Article IX-A of the 1987 Constitution, emphasizing that election cases are to be addressed by the COMELEC in divisions and that motions for reconsideration must be filed with the COMELEC en banc before a petition for certiorari can be pursued in the Supreme Court. The Court identified that failure to exhaust administrative remedies by not filing a motion for reconsideration precludes judicial review.
Court’s Conclusion and Rationale
The Supreme Court held that the COMELEC's actions were in line with constitutional provisions and that the case pr
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Case Background
- The case is a special civil action for certiorari and prohibition under Rule 65 of the 1997 Rules of Civil Procedure.
- The petitioner, Jeremias V. Esteves, challenges the Resolution of the Second Division of the Commission on Elections (COMELEC) in SPR No. 46-2007.
- The COMELEC Resolution annulled the Order of the Regional Trial Court (RTC) dated 8 September 2007, which had denied the motion to dismiss an election protest filed by Esteves against private respondent Mayor Reynaldo Teh Bitong.
Election Context
- The context of the dispute originates from the national and local elections on 14 May 2007.
- Both Esteves and Bitong contested the position of municipal mayor for the Municipality of Casiguran, Aurora.
- The Municipal Board of Canvassers declared Bitong the duly elected mayor, having received 3,342 votes—48 votes more than Esteves, who received 3,294 votes.
Procedural History
- On 25 May 2007, Esteves filed an election protest (EPC No. 99) in the RTC of Baler, Aurora, presided by Judge Corazon D. Soluren.
- The RTC issued a precautionary protection order to safeguard election materials and directed their presentation in court.
- Bitong filed an answer, which the RTC admitted on 2 August 2007, dismissing Bitong's counter-protest due to non-payment of filing fees.
Motion to Dismiss
- On 6 September 2007, Bitong filed a motion to dismi