G.R. No. L-4576

MAURO NAVARRO, plaintiff, vs. CASIANO GIMENEZ, defendant.

February 27, 1908

FACTS: Mauro Navarro (plaintiff) and Casiano Gimenez (defendant) were candidates for municipal president of Lingayen in the election held on November 5, 1907. Navarro was initially declared the winner. Gimenez subsequently filed an election protest with the Court of First Instance (CFI) of Pangasinan, as prescribed by Section 27 of the Election Law (Act No. 1582).

On January 7, 1908, the CFI rendered a final judgment, declaring Gimenez the winner with 211 legal votes against Navarro’s 203. The CFI arrived at this conclusion by rejecting 17 votes cast for Navarro due to erasures and the name “Mauro Navarro” being written by the same person on all of them, and one additional ballot due to being on yellow paper instead of white. The CFI ordered the election board to revise its returns and declare Gimenez elected.

Navarro then filed this quo warranto proceeding with the Supreme Court under the Code of Civil Procedure, alleging that the CFI erred in rejecting the 18 votes and seeking to oust Gimenez from office and be installed himself.

ISSUE: Can a quo warranto action be maintained to revisit or overturn the factual determinations made by a Court of First Instance in an election contest, given that Section 27 of the Election Law (Act No. 1582) grants the CFI “exclusive and final jurisdiction” over such contests and explicitly disallows an appeal?

RULING: The Supreme Court dismissed the quo warranto action, ruling that it cannot be maintained.

The Court held that Section 27 of the Election Law (Act No. 1582) clearly provides a summary and exclusive method for determining election contests, granting the Court of First Instance “exclusive and final jurisdiction” and explicitly stating that “No appeal is allowed from that decision.” Allowing a quo warranto action on grounds that were already tried and decided by the CFI in an election protest would effectively amount to an appeal, which is precisely what Section 27 prohibits.

The Court concluded that the provisions of Section 201 of the Code of Civil Procedure, which allow an individual to commence a quo warranto action, have been modified by Section 27 of the Election Law. Therefore, a person claiming a right to a public office cannot maintain a quo warranto action when the grounds alleged relate to facts that the Court of First Instance had the jurisdiction to determine, and did determine, in proceedings under Section 27 of the Election Law. In this case, Navarro’s grounds for the quo warranto action were solely based on the factual findings regarding the votes, which the CFI had jurisdiction to try and determine.