Case Summary (G.R. No. 118861)
Issue of COMELEC’s Jurisdiction Over Extraordinary Writs in Election Cases
The fundamental legal issue revolves around whether the COMELEC has jurisdiction to hear and decide petitions for certiorari, prohibition, and mandamus in election cases where it holds exclusive appellate jurisdiction. The Court revisited this question in light of previous rulings—specifically Garcia vs. De Jesus and Uy vs. Commission on Elections (1992), and Veloria vs. Commission on Elections (1992)—which held that COMELEC lacked jurisdiction to issue these extraordinary writs absent explicit constitutional or statutory grant. The Court recognized that appellate and original jurisdiction are mutually exclusive and that original jurisdiction to issue prerogative writs must be expressly conferred by law or the Constitution.
Statutory Basis for COMELEC’s Claimed Jurisdiction: B.P. Blg. 697, Section 50
Respondent COMELEC asserted jurisdiction based on Section 50 of B.P. Blg. 697, which explicitly vests the Commission with exclusive authority to hear and decide petitions for certiorari, prohibition, and mandamus in election cases. The petitioner counterargued that B.P. Blg. 697 was a temporary statute intended solely for the 1984 Batasang Pambansa elections and therefore self-destructed thereafter. The COMELEC maintained that the statute had not been repealed by the Omnibus Election Code (B.P. Blg. 881) and that its provisions, specifically Section 50, remain applicable and consistent with current election laws.
Election Background and Lower Court Proceedings
In the 1992 local elections for Mayor of Magallanes, petitioner Relampagos lost to respondent Cumba by a narrow margin. Petitioner subsequently filed an election protest with the Regional Trial Court (RTC), which ruled in petitioner’s favor by a six-vote margin on June 29, 1994. Upon receipt of the decision, the private respondent appealed the ruling to the COMELEC on July 4, 1994, with the trial court giving due course to the appeal on July 8, 1994. The petitioner filed a motion for execution pending appeal on July 12, 1994, which the trial court granted on August 3, 1994, resulting in the issuance of the writ of execution. The private respondent challenged this order via a petition for certiorari filed with the COMELEC.
COMELEC’s Resolution Asserting Jurisdiction and Modifying Trial Court Order
On February 9, 1995, the COMELEC promulgated a resolution asserting it had exclusive authority over certiorari, prohibition, and mandamus petitions involving election cases, and therefore, exercised jurisdiction over the petitioner’s certiorari petition. The COMELEC declared null and void the trial court’s order granting execution pending appeal and lifted the writ of execution, restoring the private respondent to her position as Mayor pending final resolution of the appeal before the Commission.
COMELEC’s Justifications and Arguments on Jurisdiction
COMELEC justified its jurisdiction by relying on Section 50 of B.P. Blg. 697, arguing the statute was not expressly repealed by the Omnibus Election Code and did not self-destruct following the 1984 election. It emphasized the principle that implied repeal of statutes is disfavored and stressed that Section 50’s grant of jurisdiction was consistent with existing election laws. The Commission contended that as the body statutorily vested with exclusive appellate jurisdiction over election cases, it was logically and functionally the proper entity to issue the extraordinary writs in question to carry out its judicial functions effectively. Furthermore, COMELEC distinguished the present case from prior rulings where certiorari petitions were filed directly against trial courts before their jurisdiction had been divested by perfected appeals.
Doctrine and Precedent on Jurisdiction and Implied Repeal
The Court revisited the doctrine that original jurisdiction must be explicitly granted by the law and rejected granting jurisdiction by implication. It underscored the rule against implied repeal, explaining that the Omnibus Election Code’s repealing clause only repeals laws inconsistent with it, and since Section 50 of B.P. Blg. 697 is not inconsistent, it remains effective. The Court clarified that legislative intent is paramount and must be ascertained by harmonizing existing statutes unless clear conflict exists. Prior case law reiterated included the principle that prerogative writs and original jurisdiction for quasi-judicial bodies require express legal authority.
Distinction Between Appellate and Original Jurisdiction of COMELEC
The Court clarified that COMELEC’s jurisdiction to issue extraordinary writs is limited to cases where such writs are issued in aid of its exclusive appellate jurisdiction over election contests under the Constitution (Article IX-C, Section 1(2)). It held that the Commission cannot exercise original jurisdiction over these writs except as necessary to perform its appellate functions effectively. The Commission’s assumption of jurisdiction in the case arose from its appellate jurisdiction over appeals from the RTC decision, aligning with its constitutional mandate to act as a court of justice in election matters.
Procedural Defects in Trial Court’s Order and Timing of Execution Pending Appeal
The Court found the trial court’s order granting execution pending appeal to have been issued with a palpable and whimsical abuse of discretion. Since the appeal to COMELEC was perfected on July 8, 1994 (when the court acknowledged due course and elevated the records), the trial court had lost jurisdiction to act upon any subsequent motions relative to execution pending appeal, including the petitioner’s motion filed on July 12, 1994. Any execution motion must be filed before the perfection of appeal; filing after divests the trial court of jurisdiction, rendering such an order invalid.
COMELEC’s Validity in Rescinding Trial Court Order and Issuing Resolution
Given COMELEC’s proper exercise of jurisdiction in aid of its exclusive appellate power, the Court upheld the Commission’s resolution nullifying the trial court’s order and lifting the writ of execution. The COMELEC’s action was deemed necessary and lawful to preserve the subject matter of the appeal and maintain the status quo pending final adjudication. The Commission’s authority to issue such writs was found to be grounded both in statute (Section 50, B.P. Blg. 697) and constitutional interpretation of its appellate jurisdiction, rebutting prior Sup
Case Syllabus (G.R. No. 118861)
Nature of the Case and Legal Issue Presented
- This case is a special civil action of certiorari under Rule 65 of the Rules of Court.
- The central issue concerns whether the Commission on Elections (COMELEC) has jurisdiction to hear and decide petitions for certiorari, prohibition, and mandamus in election cases, particularly where it exercises exclusive appellate jurisdiction.
- The case revisits and challenges previous Supreme Court rulings which rejected COMELEC’s authority to issue such extraordinary writs due to absence of explicit constitutional or statutory grant.
- The Court was tasked with resolving the conflict between two opposing interpretations: earlier Supreme Court decisions denying such jurisdiction vs. COMELEC’s reliance on Section 50 of Batas Pambansa Blg. 697 (BP Blg. 697) which purportedly grants exclusive authority over these writs.
Background and Factual Context
- The dispute arose from the synchronized elections on May 11, 1992, for Mayor of Magallanes, Agusan del Norte.
- Petitioner Emmanuel M. Relampagos and private respondent Rosita Cumba contested the election results, Cumba initially proclaimed winner by 22 votes.
- Petitioner filed an election protest in the Regional Trial Court (RTC), which ruled in his favor, declaring him winner by 6 votes.
- Respondent Cumba appealed the RTC decision to COMELEC and paid appellate docket fees; the appeal was given due course.
- Petitioner moved the trial court for execution pending appeal; the RTC granted this motion, issuing a writ of execution.
- Respondent Cumba filed a motion for reconsideration of the execution order which was denied.
- Thereafter, respondent Cumba filed a petition for certiorari with COMELEC to annul the trial court's order granting execution pending appeal and the writ issued.
- COMELEC accepted jurisdiction and granted respondent’s petition, annulling the RTC order, effectively restoring Cumba to her position pending appeal resolution.
Relevant Legal Framework and Jurisprudence
- Earlier Supreme Court rulings in Garcia vs. De Jesus and Uy vs. COMELEC (March 4, 1992) and Veloria vs. COMELEC (July 29, 1992) held that COMELEC lacks jurisdiction to issue certiorari, prohibition, and mandamus writs due to absence of express constitutional or statutory authority.
- The Garcia and Uy ruling underscored the principle that jurisdiction, whether original or appellate, must be expressly conferred and not inferred.
- The Pimentel vs. COMELEC case reaffirmed that the Constitution does not grant COMELEC original jurisdiction to issue extraordinary writs; such original jurisdiction must be explicitly stated by Constitution or law.
- COMELEC asserted as basis of jurisdiction Section 50 of BP Blg. 697, which explicitly vests the Commission with exclusive authority to hear and decide petitions for certiorari, prohibition, and mandamus involving election cases.
- COMELEC argued this provision was not repealed by the Omnibus Election Code (B.P. Blg. 881) nor was it inconsistent with existing election laws.
Analysis on the Status and Effect of Batas Pambansa Blg. 697, Section 50
- BP Blg. 697 was a temporary statute primarily governing the 1984 Batasang Pambansa elections, but included provisions, notably Section 50, which were argued to have continuing applicability.
- The Court examined whether Section 50 was repealed by the Omnibus Election Code (B.P. Blg. 881) which generally repealed inconsistent election laws, decrees, or regulations.
- The Omnibus Election Code expressly repealed Presidential Decree No. 1296 (1978 Election Code) and laws inconsistent therewith, but made specific exceptions and did not expressly repeal BP Blg. 697.
- The principle against implied repeal was applied: repeal of statute should be express or unequivocally implied and must be interpreted strictly.
- Court determined there was no irreconcilable inconsistency between Section 50 of BP Blg. 697 and the Omnibus El