Case Summary (G.R. No. 221103)
Quorum Requirement and Executive Committee Actions
Rule 6(a) requires one Justice and four members to convene; Rule 6(b) permits at least three members (including one Justice) to act as an Executive Committee when a full quorum is absent, subject to subsequent confirmation; and Rule 6(c) allows an Executive Committee of three (including one Justice) to decide urgent motions or administrative matters between regular sessions. Petitioner claimed these provisions let Justices block proceedings by absence or enable a single member to decide contests when inhibitions occur.
Jurisdictional Requisites for HRET Actions
Rule 15 defines HRET’s jurisdiction as “sole judge of contests relating to election, returns, and qualifications” and prescribes three requisites for membership: valid proclamation, proper oath, and assumption of office. Rule 17 (as amended September 20, 2018) and Rule 18 fix a 15-day filing period for election protests and quo warranto petitions measured from June 30 of the election year or, if the proclamation occurs later, from the date of proclamation. Petitioner contended that tying these deadlines to proclamation, oath, or assumption of office created uncertainty and ceded authority to COMELEC.
Equal Protection and Separation of Powers Analysis
Relying on the 1987 Constitution’s Article VI, Section 17, the Court underscored the framers’ intent to balance partisan influence by equally representing majority and minority parties and to temper decisions with judicial impartiality via three Supreme Court Justices. The quorum rule ensures participation of both Judicial and Legislative departments; it does not render Justices indispensable nor grant them veto powers. Classification between Justices (three) and Representatives (six) is a reasonable distinction germane to the rule’s purpose and does not violate equal protection under Article III, Section 1 of the Constitution.
Clarification of Ambiguity in Rule 69
Rule 69 requires concurrence of at least five members for decisions, with a majority of remaining members sufficient when a member inhibits. The Court held that an inhibiting member is not “present” for quorum purposes, and that Special Members may be designated to maintain the required quorum. Thus, there is no scenario in which a single member’s vote controls the Tribunal.
Filing Periods for Election Contests
The decision recognized that the origina
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Procedural Background
- Petitioner filed a petition for certiorari before the Supreme Court challenging the constitutionality of provisions in the 2015 Revised Rules of the House of Representatives Electoral Tribunal (HRET).
- Two quo warranto cases against petitioner were pending before HRET: Case No. 13-036 (Noeme Mayores Tan and Jeasseca L. Mapacpac v. Regina Ongsiako Reyes) and Case No. 13-0037 (Eric D. Junio v. Regina Ongsiako Reyes).
- The Office of the Solicitor General moved to be excused from representing the HRET and was relieved by the Court; HRET thereafter filed its own Comment.
Antecedent Facts
- On November 1, 2015, HRET published its 2015 Revised Rules, including:
• Rule 6 on meetings, quorum, and executive‐committee actions
• Rule 15 on jurisdiction and member qualifications
• Rules 17 and 18 on the periods to file election protests and quo warranto
• Rule 69 on votes required for decisions - Petitioner contends these provisions grant undue powers to Supreme Court Justices, create ambiguity, and expand COMELEC’s jurisdiction.
Petitioner’s Contentions
- Rule 6(a) unconstitutionally makes at least one Justice indispensable to constitute a quorum, thereby giving Justices veto power by mere absence.
- The quorum formula is ambiguous because “four members” need not all be legislators and inhibited or disqualified members may be counted.
- Rule 15, in relation to Rules 17 and 18, shifts the reckoning period for filing protests or quo warranto to dates tied to oath‐taking or assumption of office, enabling COMELEC to encroach on HRET’s domain.
- The changes allegedly violate the equal protection clause and may prejudice pending cases.
Respondent’s Arguments (HRET)
- HRET has constitutional authority to promulgate its own procedural rules.
- The quorum requirement reflects the constitutional composition of three Justice‐members and six legislative members, preserving judicial–legislative balance.
- The charge of veto power by absence is speculative and imputes bad faith to the Justices.
- Rule 15’s requisites for membership are within HRET’s power to define the effective commencement of its jurisdiction.
Issue
Wh