G.R. No. L-84297, December 8, 1988
Carmelo F. Lazatin, petitioner, vs. The House Electoral Tribunal and Lorenzo G. Timbol, respondents.

FACTS

Petitioner Carmelo F. Lazatin and private respondent Lorenzo G. Timbol were candidates for Representative of Pampanga’s first district in the May 11, 1987 elections. Lazatin was proclaimed winner on May 27, 1987. Timbol filed a petition with the Commission on Elections (COMELEC) to annul this proclamation. On September 15, 1987, the COMELEC declared Lazatin’s proclamation void ab initio. Lazatin challenged this before the Supreme Court in G.R. No. 80007 , which, on January 25, 1988, set aside the COMELEC resolution and effectively reinstated the proclamation.
On February 8, 1988, Timbol filed an election protest with the House Electoral Tribunal (HRET), docketed as Case No. 46. Lazatin moved to dismiss, arguing the protest was filed late under Section 250 of the Omnibus Election Code, which prescribes a ten-day period from proclamation. The HRET denied the motion, ruling the protest was timely under its own Section 9 of the HRET Rules, which provided a fifteen-day period from the effectivity of the rules or from the date of proclamation. The HRET reasoned that the COMELEC’s annulment suspended the proclamation’s effectivity until the Supreme Court’s reinstatement on January 28, 1988, making Timbol’s February 8 filing within the allowed period.

ISSUE

Whether the HRET committed grave abuse of discretion in assuming jurisdiction over Timbol’s election protest by applying its own procedural rules instead of the statutory period under the Omnibus Election Code.

RULING

The Supreme Court dismissed the petition, upholding the HRET’s jurisdiction. The legal logic centers on the constitutional independence and rule-making authority of electoral tribunals. The 1987 Constitution grants the HRET the sole and exclusive jurisdiction to be the judge of all contests relating to the election, returns, and qualifications of its members. This plenary power necessarily includes the authority to promulgate its own procedural rules to govern the filing and disposition of election contests. Section 9 of the HRET Rules, providing a specific fifteen-day period for protests arising from the 1987 elections, is a valid exercise of this constitutional rule-making power.
The Court ruled that the HRET’s procedural rules, not the general statute (Section 250 of the Omnibus Election Code), govern the filing period for protests within its exclusive domain. The statutory ten-day period applies to contests before the COMELEC, not before the constitutional body that is the HRET. The HRET did not commit grave abuse of discretion in applying its own rules and in its factual determination that the period should be reckoned from the final reinstatement of the proclamation. The Court emphasized that the HRET’s judgments on matters within its jurisdiction are beyond judicial interference absent a clear showing of grave abuse of discretion amounting to lack or excess of jurisdiction. No such abuse was demonstrated in the HRET’s interpretation and application of its procedural rules to the specific chronology of this case.