G.R. No. L-12596; July 31, 1958
JOSE L. GUEVARA, petitioner, vs. THE COMMISSION ON ELECTIONS, respondent.

FACTS

Petitioner Jose L. Guevara published an article entitled “Ballot Boxes Contract Hit” in the June 2, 1957 issue of the Sunday Times. The Commission on Elections (COMELEC) issued an order for him to show cause why he should not be punished for contempt. The COMELEC alleged the article tended to interfere with and influence its members in adjudicating a pending controversy arising from a third petition for reconsideration filed by Acme Steel Mfg. Co., Inc. (ACME) regarding the award of contracts for ballot boxes. The controversy involved COMELEC’s resolutions of May 4 and 13, 1957, awarding contracts to National Shipyards & Steel Corporation (NASSCO) and Asiatic Steel Mfg. Co., Inc. (ASIATIC), and subsequent petitions by ACME for reconsideration. Petitioner filed a motion to quash, challenging COMELEC’s jurisdiction to punish for contempt, arguing the power was unconstitutional as applied, that COMELEC was acting administratively in purchasing ballot boxes, that the matter was a closed case when the article was published, and that the article was a fair report. COMELEC denied the motion but allowed petitioner to elevate the jurisdictional issue to the Supreme Court, leading to this petition for prohibition with preliminary injunction.

ISSUE

Whether the Commission on Elections has the power and jurisdiction to conduct contempt proceedings against the petitioner for the publication of the article in question.

RULING

No. The Supreme Court granted the petition and permanently enjoined the COMELEC from proceeding with the contempt case. The Court held that while the COMELEC, as an independent constitutional body, has quasi-judicial functions over election-related controversies and is granted by statute (Section 5 of Republic Act No. 180, the Revised Election Code) the power to punish contempts under the same procedure and penalties as courts, this power is inherently judicial in nature. The Court ruled that in the specific matter of purchasing ballot boxes—the subject of the pending controversy—the COMELEC was discharging a purely administrative or ministerial duty, not exercising a judicial function. Consequently, it could not validly exercise the power to punish for contempt, as such power is an incident of judicial proceedings intended to preserve order and enforce judgments in the administration of justice. The exercise of contempt power by an administrative body to further its administrative functions was declared invalid.