G.R. No. 191618 - Macalintal vs. Presidential Electoral Tribunal

Section 4(7) grants the Supreme Court sitting en banc exclusive original jurisdiction over presidential and vice-presidential contests and authority to promulgate rules.
Verba legis and constitutional‐construction principles mandate giving effect to ordinary meaning and harmonizing related provisions.
The 1987 framers intended to constitutionalize existing statutory arrangements (R.A. 1793 and B.P. Blg. 884), not to prohibit institutional specificity.
Supplementary rule-making authority empowers the Court to organize a functional tribunal with personnel, seal, budget, and procedures.

Section 12 prohibits designating justices to agencies performing quasi-judicial or administrative functions, unless the Constitution itself so provides.
Article VII, Section 4(7) expressly appoints the Supreme Court justices to sit as the PET; by constitutional exception, they are exempt from Section 12’s prohibition.
Parallel constitutional provisions vest justices in the Senate and House Electoral Tribunals, affirming that electoral tribunals are independent constitutional bodies distinct from separation-of-powers concerns.

Rule-making is implicit in any grant of jurisdiction; the Constitution’s express reference removes legislative interference.
Constitutional‐Commission debates confirm intent: the PET must promulgate its own rules for procedure, staffing, and operations to fulfill its adjudicatory mandate.
Plenary judicial power includes all necessary means to effectuate constitutional functions (cf. McCulloch v. Maryland doctrine of necessary implication).

1935 Constitution omitted a tribunal for presidential contests; Congress enacted R.A. 1793 (1957) to fill the gap, vesting jurisdiction in the Supreme Court justices.
1973 Constitution’s parliamentary shift rendered PET unnecessary; B.P. Blg. 884 (1985) recreated it under the National Assembly.
1987 Constitutional Commission intentionally elevated the PET to a constitutional institution, preserving statutory features (budget allocation, clerk, procedural powers) within Article VII, Section 4(7).

Composition: Supreme Court justices sitting en banc as Chairman and Members of the PET.
Administrative staff and seal: technical adjuncts to identify tribunal proceedings without creating a separate court.
Budgetary allocation and personnel appointments: necessary to staff and operate the tribunal independently and efficiently.
Not a distinct branch or separate court, but a specialized function of the Supreme Court under plenary judicial power.

Resolving election contests is a quintessential exercise of judicial power, involving adversarial proceedings and enforceabl

Atty. Romulo B. Macalintal filed an undesignated petition (G.R. No. 191618) challenging the constitutionality of the Presidential Electoral Tribunal (PET) created under Section 4(7), Article VII of the 1987 Constitution.
Petitioner alleged that the PET, by having its own budget, seal, personnel, and confidential employees, effectively operates as a separate tribunal beyond the Supreme Court’s constitutional authority.
He cited specific provisions of the 2005 PET Rules to demonstrate unauthorized powers:
- Rule 3: designates the Chief Justice and Associate Justices as “Chairman and Members” of the PET.
- Rule 8(e): authorizes the Chairman to appoint employees and confidential staff.
- Rule 9: establishes an independent administrative staff with a Clerk and Deputy Clerk.
- Rule 11: provides a distinct PET seal.
While conceding the Supreme Court may appoint “additional personnel,” petitioner insisted these rules went further than the Constitution permits.

Locus standi: Does petitioner have legal standing to challenge the PET’s constitutionality?
Constitutionality of the PET’s creation: Does establishing the PET violate Section 4(7), Article VII by unlawfully constituting a separate tribunal?
Designation of justices: Does assigning Supreme Court Justices as PET members contravene Section 12, Article VIII’s prohibition against designating justices to agencies performing quasi-judicial or administrative functions?

The PET’s structure exceeds the constitutional grant that the Supreme Court, “sitting en banc,” may promulgate rules but not create a distinct tribunal.
The use of titles “Chairman” and “Members,” a separate seal, dedicated budget, and independent personnel illustrate an unauthorized entity.
Section 12, Article VIII prohibits justices from serving in any extra-judicial quasi-judicial or administrative body.
Relied on Buac v. COMELEC’s reference to the PET exercising “quasi-judicial power” to support his constitutional claim.
Asserted standing as a citizen, taxpayer, and member of the Bar, invoking the transcendental importance of issues.

The petition is unspecified, lacks statutory basis, and violates pleading rules.
Petitioner failed to demonstrate any personal or direct injury and therefore lacks locus standi.
Petitioner had previously appeared before the PET in Poe v. Macapagal-Arroyo (2005) and accepted its jurisdic