Case Summary (G.R. No. L-32370)
Legal Issues Presented
The petition primarily raises two significant legal questions: (1) the legality and constitutionality of Section 24 of Resolution No. 2499 of the Commission on Elections (COMELEC), which assigned the Board of Election Supervisors (BES) as the final arbiter of all election disputes concerning Sangguniang Kabataan (SK) elections; and (2) the jurisdiction of Regional Trial Courts (RTC) over contests arising from SK elections.
Background of the Case
Jose M. Mercado was declared the winner of the Sangguniang Kabataan (SK) elections held on December 4, 1992, in Barangay Mabalor, Ibaan, Batangas, with a narrow margin of one vote against Crisanto P. Pangilinan. Following Mercado's proclamation, Pangilinan initiated a protest with the BES, alleging misconduct during the counting of votes. The BES subsequently conducted a recount, which resulted in the reversal of the election outcome, proclaiming Pangilinan as the duly elected SK Chairman.
Initial Legal Action
In response to the BES's proclamation of Pangilinan, Mercado filed a petition for certiorari and mandamus before the RTC of Batangas City, seeking to annul the BES decision and compel recognition of his election. Mercado contended that the BES lacked jurisdiction over the protest, which he argued should have been resolved by the Metropolitan or Municipal Trial Court per Section 252 of the Omnibus Election Code. He further claimed that he was denied due process because the BES did not give him a chance to be heard during the recount process.
RTC Proceedings
The RTC subsequently dismissed Mercado's petition for lack of jurisdiction, concluding that it was bound by Resolution No. 2499 of the COMELEC, which vested the BES with the authority to handle SK election disputes. Mercado's motion for reconsideration was also denied, reaffirming that the reopening of the ballot box and recounting of votes fell within the BES's jurisdiction.
Petition and Arguments before the Supreme Court
Mercado then filed a Rule 45 petition with the Supreme Court to review the RTC's dismissal orders. He reiterates that the BES's authority under Resolution No. 2499 is unconstitutional for conflicting with both the Omnibus Election Code and the 1987 Constitution, which he contends specify that courts, not an administrative body, have jurisdiction over disputes regarding elective barangay officials. He argues that the SK election does not constitute an election of barangay officials under these provisions, and therefore, the exclusive jurisdictional framework set out for barangay officials does not apply to SK officials.
Supreme Court's Analysis and Ruling
The Supreme Court determined that the SK's creation and evolution did not classify the SK Chairman as an elective barangay official under existing statutory definitions. The Court recognized that while the BES had quasi-
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Case Overview
- The case revolves around the legality and constitutionality of Section 24 of Resolution No. 2499 by the Commission on Elections (COMELEC) which established Boards of Election Supervisors (BES) for the Sangguniang Kabataan (SK) elections as the final arbiter of all election protests.
- The jurisdiction of Regional Trial Courts (RTC) over contests involving SK elections is also scrutinized.
Background of the Case
- Petitioner Jose M. Mercado was proclaimed as the winner of the SK election for Barangay Mabalor, Ibaan, Batangas, on December 4, 1992, by the Board of Election Tellers (BET) with a narrow margin (49 to 48 votes).
- The victory was challenged by private respondent Crisanto P. Pangilinan, who filed a formal protest with the BES alleging misconduct by the BET Chairman during the vote counting.
- The BES conducted a recount, which overturned the initial results, declaring Pangilinan as the winner with 51 votes to Mercado's 49.
Legal Proceedings
- Mercado filed a petition for certiorari and mandamus before the RTC of Batangas City, contesting the BES's jurisdiction over the election protest and claiming violations of due process.
- The RTC dismissed Mercado's petition for lack of jurisdiction, stating that the BES had exclusive authority over such protests as per COMELEC's Resolution No. 2499.
Key Legal Issues
- The case presen