GUERRERO v. COMELEC
G.R. No. 137004, July 26, 2000
FACTS:
Guillermo
Ruiz file a petition to disqualify respondent Rodolfo Fariñas as a candidate
for the position of Congressman in the First District of Ilocos Norte. Ruiz
alleged that Fariñas had been campaigning as a candidate for Congressman in the
May 11, 1998 polls, despite his failure to file a certificate of candidacy for
said office. On May 8, 1998 or 3 days before the election, Farinas filed his
certificate of candidacy substituting candidate Chevylle Farinas who withdrew
on April 3, 1998. On May 10, 1998, the COMELEC dismissed the petition of Ruiz.
After
the election, Farinas was duly proclaimed winner. Ruiz filed a motion for
reconsideration, contending that Farinas could not validly substitute for
Chevylle Farinas, since the latter was not the official candidate of LAMMP, but
was an independent candidate. On June 3, 1988, Farinas took his oath of office
as a member of the House of Representatives. Comelec dismissed the MR on the
ground that the matter is now within the exclusive jurisdiction of the House of
Representative Electoral Tribunal.
ISSUES:
Did
the COMELEC commit grave abuse of discretion in holding that the determination
of the validity of the certificate of candidacy of respondent Fariñas is
already within the exclusive jurisdiction of the Electoral Tribunal of the
House of Representatives?
HELD:
There
is no grave abuse of discretion on the part of the COMELEC when it held that
its jurisdiction over the case had ceased with the assumption of office of
respondent Farinas as Representative for the first district of Ilocos Norte.
While COMELEC is vested with the power to declare valid or invalid a
certificate of candidacy, its refusal to exercise that power following the
proclamation and assumption of the position by Farinas is a recognition of the jurisdictional
boundaries separating the COMELEC and the HRET. Under Art. VI, Sec. 17 of the
Constitution, the HRET has sole and exclusive jurisdiction over all contests
relative to the election, returns and qualifications of members of the House of
Representatives. Thus, once a winning candidate has been proclaimed, taken
his oath, and assumed office as a member of the House of Representatives,
COMELEC’s jurisdiction over election contests relating to his election, returns
and qualifications ends, and the HRET’s own jurisdiction begins. Thus, the
COMELEC’s decision to discontinue exercising jurisdiction over the case is
justifiable, in deference to the HRET’s own jurisdiction and functions.
In
an electoral contest where the validity of the proclamation of a winning
candidate who has taken his oath of office and assumed his post as Congressman
is raised, that issue is best addressed to the HRET. The reason for this ruling
is self-evident, for it avoids duplicity of proceedings and a clash of
jurisdiction between constitutional bodies, with due regard to the people’s
mandate.
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