GR 134932; (February, 2000) (Digest)
G.R. No. 134932. February 18, 2000. VITO BESO, petitioner, vs. RITA ABALLE and HON. ROBERTO A. NAVIDAD, Acting Presiding Judge, Branch 31, Regional Trial Court of Calbayog City, respondents.
FACTS
Petitioner Vito Beso and private respondent Rita Aballe were candidates for Barangay Captain in the May 1997 elections. Aballe was proclaimed winner by one vote. Beso filed an election protest with the Municipal Trial Court (MTC), which later decided in his favor, declaring him the duly elected Barangay Captain. Aballe filed a notice of appeal to the Commission on Elections (COMELEC) and paid the corresponding appeal fees, thereby perfecting her appeal.
Subsequently, Beso filed a motion for execution pending appeal in the MTC, which was granted. Aballe then filed a petition for certiorari and prohibition with the Regional Trial Court (RTC) to annul the MTC’s order granting execution pending appeal. The RTC, presided by respondent Judge Navidad, issued a temporary restraining order and later a decision setting aside the MTC’s execution order.
ISSUE
Whether the Regional Trial Court had jurisdiction to entertain the special civil action for certiorari and prohibition assailing the MTC’s order granting execution pending appeal in an election protest involving a barangay official.
RULING
No. The Supreme Court ruled that the RTC acted without jurisdiction. Under the Constitution and pertinent laws, the COMELEC has exclusive appellate jurisdiction over all contests involving elective barangay officials decided by trial courts of limited jurisdiction. Since the MTC, a court of limited jurisdiction, originally decided the election protest for Barangay Captain, the COMELEC possessed exclusive appellate jurisdiction over the case. Consequently, the RTC had no authority to entertain Aballe’s petition for certiorari, which was essentially a challenge to an interlocutory order (the grant of execution pending appeal) issued within the main election protest case. The proper remedy for Aballe was to seek relief directly from the COMELEC. The Supreme Court emphasized that the RTC’s assumption of jurisdiction constituted grave abuse of discretion. The Court nullified the RTC’s orders and decision and directed the dismissal of the special civil action.