Case Summary (G.R. No. 172131)
Factual Background
Liwayway Vinzons-Chato, a candidate in the aforementioned elections, alleged that during the canvassing of votes by the Municipal Board of Canvassers (MBC) of Labo from May 10 to 12, 2004, her counsel identified several manifest errors and discrepancies in the election returns. Despite objections raised, the MBC concluded its canvassing and forwarded the results to the Provincial Board of Canvassers (PBC) without allowing Chato or her counsel sufficient time to present their objections. On May 14, 2004, the PBC denied Chato's petition for reconsideration and proclaimed Renato Unico as the elected representative for the district.
Procedural Antecedents
Chato subsequently filed a petition with COMELEC asserting that the election returns were fraught with manifest errors, including discrepancies regarding votes counted and ballots cast. COMELEC initially ordered the suspension of Unico's proclamation but later lifted this order, explaining that jurisdiction had shifted due to Unico's proclamation and oath of office. On April 13, 2005, having found Chato's petition lacking in merit, COMELEC dismissed it, establishing that matters addressed involved a re-count rather than merely correcting manifest errors.
COMELEC's Dismissal
The COMELEC en banc, in a resolution dated March 17, 2006, affirmed the dismissal by stating that it had lost jurisdiction to adjudicate cases regarding election returns and qualifications of members of the House of Representatives once a candidate was proclaimed and had assumed office. This decision was based on previous rulings establishing that the House of Representatives Electoral Tribunal (HRET) holds exclusive jurisdiction over such election contests.
Legal Issues Raised by Petitioner
In her petition for certiorari, Chato argued that the COMELEC committed grave abuse of discretion by erroneously ruling that it lacked jurisdiction following Unico's oath-taking. She claimed Unico's proclamation was void due to irregularities in the election results and that the COMELEC retained authority over issues concerning manifest errors and the validity of proclamations.
Jurisdiction and Electoral Tribunals
The ruling clarified that according to Section 17, Article VI of the 1987 Philippine Constitution, the Senate and House of Representatives each have electoral tribunals which exclusively handle contes
...continue readingCase Syllabus (G.R. No. 172131)
Case Overview
- The case involves a petition for certiorari filed by Liwayway Vinzons-Chato against the Commission on Elections (COMELEC) and Renato J. Unico.
- The petitioner seeks to nullify the COMELEC en banc's Resolution dated March 17, 2006, which affirmed a prior dismissal of her petition regarding election returns in Labo, Camarines Norte.
- The case pertains to the May 10, 2004 elections for the congressional district of Camarines Norte.
Factual Background
- Liwayway Vinzons-Chato and Renato J. Unico were candidates for the lone congressional district during the elections.
- Chato raised objections during the canvassing of election returns, citing manifest errors and discrepancies.
- The Municipal Board of Canvassers (MBC) of Labo provided a timeframe for Chato's counsel to present evidence but concluded canvassing prematurely.
- The Provincial Board of Canvassers (PBC) denied Chato's motion to suspend proceedings and subsequently proclaimed Unico as the winner.
Procedural History
- Chato filed a petition with the COMELEC alleging multiple manifest errors in the election returns.
- The COMELEC initially suspended Unico's proclamation but later lifted the order, stating that jurisdic