Case Summary (G.R. No. 224900)
Factual Background
After winning the Congressional elections, Lazatin took his oath of office and assumed his responsibilities. However, Buan, Jr. and Timbal contended that the COMELEC acted prematurely in proclaiming Lazatin without resolving their protests against the election returns. They claimed the situation rendered Lazatin's petition moot and academic, given the finality of the COMELEC resolution.
Jurisdictional Issues
The petitioner argued that only the House Electoral Tribunal possesses jurisdiction over election contests as per Section 17, Article VI of the 1987 Philippine Constitution. The rival candidates and the Office of the Solicitor General contended various points regarding the validity of the proclamation. They argued that the proclamation lacked the requisite resolution regarding the contested election returns, claiming that the actions taken by the COMELEC were inappropriate.
Legal Arguments
The Solicitor General emphasized the validity of the proclamation, asserting that the COMELEC's Telex Order granted authority to the canvassing board to declare the winner per Section 245 of the Omnibus Election Code. The COMELEC, conversely, asserted that Lazatin's proclamation was illegal and void due to unresolved protests. The petitioner’s Consolidated Reply reiterated earlier arguments emphasizing the legitimacy of his proclamation and the necessity for the Electoral Tribunal to handle the competing election contests.
Supreme Court Resolutions
The Supreme Court, in a resolution dated November 17, 1987, determined that it would give due course to Lazatin's petition. The Court concluded that the petitioner’s proclamation, alongside his subsequent oath-taking and assumption of duties, warranted respect for the House Electoral Tribunal’s authority. The Court explicitly rejected the notion that it possessed the jurisdiction to intervene in what was deemed a matter of electoral protest, which was within the purview of th
...continue readingCase Syllabus (G.R. No. 224900)
Case Citation
- Jurisdiction: Supreme Court of the Philippines
- Date: January 25, 1988
- G.R. No.: 80007
- Report: 241 Phil. 343 (En Banc)
Parties Involved
- Petitioner: Carmelo F. Lazatin
- Respondents: The Commission on Elections (COMELEC), Francisco R. Buan, Jr., Lorenzo G. Timbol
Background of the Case
- Petitioner Carmelo F. Lazatin filed a petition challenging the jurisdiction of the Commission on Elections (COMELEC) to annul his proclamation as Congressman after he had already taken his oath of office and assumed his duties.
- The petitioner contended that the House Electoral Tribunal is the sole judge in all election contests, as stipulated in Section 17, Article 6 of the 1987 Constitution.
Contentions of the Respondents
Comments by Buan, Jr. and Timbol:
- Argued that the petition has become moot and academic because the COMELEC Resolution had already become final and executory following a temporary restraining order issued by the Supreme Court on October 6, 1987.
- Claimed that the COMELEC proclaimed Lazatin without resolving their separate written protests against the election returns in Pampanga, which were docketed as SPC Nos. 87-234, 87-358, and 87-351.
Comment of the Solicitor General:
- Asserted that the petition should proceed as the proclamation of Lazatin was valid.
- Exp