G.R. No. 118597 July 14, 1995
JOKER P. ARROYO, petitioner, vs. HOUSE OF REPRESENTATIVES ELECTORAL TRIBUNAL (HRET) and AUGUSTO L. SYJUCO, JR., respondents.

FACTS

Petitioner Joker P. Arroyo was proclaimed the duly elected Congressman for Makati’s lone district after the May 1992 elections. Private respondent Augusto L. Syjuco, Jr. filed an election protest before the House of Representatives Electoral Tribunal (HRET), seeking a revision and recount of ballots from 1,292 precincts based on alleged irregularities and fraud. During the revision process, a subsequent investigation by retired Justice Emilio Gancayco uncovered serious anomalies engineered by some HRET personnel, including the pilfering, dumping, and marking of ballots to reduce Arroyo’s votes.
After the revision, with three precincts left, Syjuco moved to withdraw these remaining precincts, claiming he had overtaken Arroyo’s lead. The parties proceeded to present evidence. Syjuco offered voluminous documentary exhibits, which were largely unauthenticated photocopies. Despite Arroyo’s objections, the HRET admitted this evidence. In his final memorandum, Syjuco abandoned reliance on the traditional ballot revision and instead urged the HRET to decide the case based on his “Precinct-Level Document-Based Evidences.”

ISSUE

Whether the HRET committed grave abuse of discretion in admitting and relying on private respondent’s unauthenticated documentary evidence to overturn the results of the election.

RULING

Yes. The Supreme Court granted the petition, annulling the HRET decision. The legal logic is anchored on the hierarchy of evidence in election contests and the constitutional mandate for the HRET to be the sole judge of all contests relating to the election, returns, and qualifications of its members. The Court held that while the HRET enjoys considerable latitude in its proceedings, its authority is not absolute and must be exercised within the bounds of law and the Constitution.
The HRET gravely abused its discretion by basing its ruling on evidence that lacked probative value. Syjuco’s documents were mere photocopies, neither certified nor authenticated by any witness, and thus inadmissible as best evidence. More critically, the HRET violated the fundamental principle that in election protests, the best and most conclusive evidence are the ballots themselves. By allowing Syjuco to shift the entire basis of his protest from the revised ballots to these unreliable documents, the HRET disregarded the statutory preference for ballots and election returns. This departure from the established hierarchy of evidence, coupled with the proven irregularities in the revision process that prejudiced Arroyo, rendered the HRET’s decision a denial of due process and a capricious exercise of power. The Court emphasized that the constitutional grant of authority to the HRET is not a license for arbitrariness.