Case Summary (G.R. No. 105278)
Background of the Case
The case arose from allegations against Feliciano Belmonte, Jr., with registered voters filing a petition for his disqualification based on alleged violations of the Omnibus Election Code, specifically Section 68, which prohibits the giving of material rewards to influence voters. The petitioners claimed that Belmonte had provided incentives to voters during campaign events. After the petitions were filed, the COMELEC directed a preliminary investigation but failed to act on an urgent motion filed by the petitioner to suspend the canvassing of election returns pending the resolution of the disqualification petitions.
Legal Issues Presented
Pangilinan's petition presents several legal issues, including a claim that the COMELEC had failed to perform its duty to hear the disqualification case and a challenge to the constitutionality of Section 15 of R.A. No. 7166, which prohibits pre-proclamation controversies in elections for congressmen. The petitioner also argues that he did not receive due process regarding the formation and operation of canvassing committees by the Board of Canvassers.
Jurisdictional Matters
A central issue in the petition is whether the COMELEC holds jurisdiction over electoral controversies concerning congressional candidates under the 1987 Constitution. The petitioner relies on Article IX-C, Section 3 of the 1987 Constitution, which states that the COMELEC has the authority to expedite and decide election cases, including pre-proclamation controversies. However, this section must be read in conjunction with Article IX-C, Section 2, which delineates the exclusive jurisdiction over election contests of different levels of government officials, specifically excluding congressmen whose electoral disputes are under the jurisdiction of the House of Representatives’ Electoral Tribunal as per Article VI, Section 17 of the 1987 Constitution.
Constitutional Interpretation
Upon analysis, the Court found that the control over election disputes concerning members of the House of Representatives rests solely with their Electoral Tribunal. Thus, the prohibition of pre-proclamation cases in Section 15 of R.A. No. 7166 is consistent with the constitutional framework established under the 1987 Constitution. This indicates that the COMELEC does not have ju
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Case Overview
- The case revolves around a petition for certiorari, prohibition, and mandamus filed by Francis Pancratius N. Pangilinan against the Commission on Elections (COMELEC), the Board of Canvassers of Quezon City, and Feliciano Belmonte, Jr.
- The petition seeks to compel COMELEC to address a disqualification petition against Belmonte, declare unconstitutional certain provisions of the election law, and to halt the canvassing and proclamation of the election results.
Background and Parties Involved
- Petitioner: Francis Pancratius N. Pangilinan, a candidate for congressman in the 11 May 1992 elections for the fourth legislative district of Quezon City.
- Respondents: Feliciano Belmonte, Jr., also a candidate for congressman, and the COMELEC, which oversees the conduct of elections.
- Key Events Leading to the Petition:
- On 23 April 1992, registered voters filed a petition for disqualification against Belmonte for alleged violations of the Omnibus Election Code.
- Complaints alleged that Belmonte engaged in vote-buying by distributing material benefits, including rice, money, and gifts.
Legal Proceedings and Petitions
- Initial Actions:
- The COMELEC referred the disqualification petition for preliminary investigation.
- On 20 May 1992, Pangilinan filed a motion to suspend the canvassing of election returns to prevent the disqualification petition from becoming moot.
- Further Developments:
- Additional petitions for