GR 109026; (January, 1994) (Digest)
G.R. No. 109026 January 4, 1994
FRANCO L. LOYOLA, petitioner, vs. THE HONORABLE HOUSE OF REPRESENTATIVES ELECTORAL TRIBUNAL and RENATO DRAGON, respondents.
FACTS
Petitioner Franco L. Loyola, a candidate for representative of the Second District of Cavite in the May 11, 1992 elections, filed an electoral protest before the House of Representatives Electoral Tribunal (HRET) against the proclaimed winner, private respondent Renato Dragon. Private respondent filed a motion for an extension of time to file his answer, which was denied by the HRET under its rules prohibiting such extensions. Private respondent nonetheless filed his answer beyond the prescribed period. The HRET, per its Resolution, did not admit the answer and deemed a general denial to have been entered for the protestee, pursuant to Rule 27 of its Revised Rules. Petitioner then filed an Omnibus Motion, arguing that the entry of a general denial was equivalent to an admission of all the allegations in the protest, and prayed for a decision disqualifying private respondent and declaring himself the duly elected representative. The HRET denied this motion and set the case for preliminary conference and presentation of evidence. Hence, petitioner filed this petition for certiorari.
ISSUE
Whether or not an entry of general denial in election cases, due to the protestee’s failure to file an answer on time, is equivalent to an admission of all the allegations in the protest.
RULING
No. The Supreme Court dismissed the petition for lack of merit. It ruled that a general denial, as entered under Rule 27 of the HRET Revised Rules, puts in issue all the material averments of the protest and permits the protestee to present evidence to disprove those allegations. It does not amount to an admission. The Court cited the established doctrine in Ibasco v. Ilao, which interpreted a similar provision in the Revised Election Code, holding that a general denial allows the protestee to present disproving evidence but not to prove affirmative defenses. The Court rejected petitioner’s argument that the HRET rules indicated an intent to decide cases based merely on pleadings, noting that nothing in the cited rules showed a legislative intent to decide without a hearing. The Court emphasized that election cases, while summary, must follow prescribed rules, and the primordial policy is to ascertain the will of the people, not to let technicalities defeat justice. The interpretation of a general denial as not an admission remains a sound and applicable principle.