Case Summary (G.R. No. 91889)
Background of the Case
During the canvassing of election returns, Timbol raised objections to the inclusion of certain election returns, which were not addressed by the Municipal Board of Canvassers. Consequently, he appealed to the Commission on Elections (COMELEC), which initially ordered the suspension of Lazatin’s proclamation but subsequently allowed the canvassing to continue. Lazatin was proclaimed as the Congressman-elect on May 27, 1987. Afterward, Timbol initiated further legal actions contesting this proclamation, ultimately leading to the COMELEC declaring Lazatin's proclamation void on September 15, 1987.
Jurisdictional Challenge
Lazatin contended that the House of Representatives Electoral Tribunal (HRET) lacked jurisdiction over Timbol's protest, based on the argument that it was filed beyond the statutory limit outlined in Section 250 of the Omnibus Election Code. This section requires election contests to be filed within ten days after the proclamation of election results. He argued that even considering time extensions and the suspension of the filing period due to his ongoing legal battles, Timbol’s protest was still untimely.
HRET's Ruling
The HRET ruled that the protest was filed within the proper time frame according to Section 9 of the HRET Rules, which allowed for a fifteen-day period for filing election contests resulting from the 1987 Congressional elections. The HRET determined that since the issues surrounding Lazatin's proclamation were unresolved due to the earlier COMELEC declaration, the effective date for which the period of filing should be counted began when the Supreme Court annulled the COMELEC's decision on January 28, 1988.
Supreme Court Analysis
The Supreme Court analyzed whether Section 250 of the Omnibus Election Code or Section 9 of the HRET Rules governed the timeliness of Timbol’s protest. It concluded that the provisions of the Omnibus Election Code relating to the COMELEC's jurisdiction had ceased to be relevant under the 1987 Philippine Constitution, which established separate jurisdiction for electoral contests involving congressional representatives through their respective electoral tribunals. Therefore, the jurisdiction of the HRET was upheld as being within constitutional bounds.
Authority of HRET
The Supreme Court affirmed the HRET's power to prescribe its own rules and timelines regarding election protests, emphasizing that such authority is a necessary implication of its broader jurisdiction granted by the Constitution. Historical precedent and the established role of electoral tribunals under previous constitutions reinforced the notion that the HRET is the sole judge of electoral contests per
...continue readingCase Syllabus (G.R. No. 91889)
Case Background
- The case involves Carmelo F. Lazatin (petitioner) and Lorenzo G. Timbul (private respondent), both candidates for Representative of the first district of Pampanga during the May 11, 1987 elections.
- During the canvassing of votes, Timbul objected to the inclusion of certain election returns, but the Municipal Board of Canvassers did not rule on his objections.
- Timbul escalated his objections to the Commission on Elections (COMELEC), which initially ordered to suspend the proclamation of the winning candidate on May 19, 1987.
- On May 26, 1987, COMELEC reversed its order, allowing the proclamation to proceed.
- Lazatin was proclaimed Congressman-elect on May 27, 1987.
- Timbul filed a petition with COMELEC to declare Lazatin’s proclamation void ab initio and later sought to prevent Lazatin from assuming office.
- Despite the lack of action from COMELEC on the second petition, Lazatin assumed office on June 30, 1987.
- On September 15, 1987, COMELEC declared Lazatin's proclamation void ab initio, prompting Lazatin to challenge this decision in the Supreme Court.
Jurisdictional Challenge
- The main issue revolves around the jurisdiction of the House of Representatives Electoral Tribunal (HRET) over an election protest filed by Timbul.
- Lazatin claimed that Timbul's protest was filed late according to Section 250 of the Omnibus Election Code, which requires that election contests be fi