G.R. No. 124169, April 18, 1997
ASAN “SONNY” CAMILIAN, petitioner, vs. COMMISSION ON ELECTIONS and LEONARDO A. PIOQUINTO, respondents.

FACTS

This case originated from an election protest filed by Leonardo A. Pioquinto against Asan “Sonny” Camilian concerning the results for the Office of the Municipal Mayor of Balabagan, Lanao del Sur, in the 1995 elections. The Regional Trial Court (RTC) rendered a decision in favor of Pioquinto, declaring him the duly elected mayor. Subsequently, the RTC granted Camilian’s motion for execution pending appeal, allowing Pioquinto to assume office immediately despite the pending appeal.
Pioquinto elevated the matter to the Commission on Elections (COMELEC), challenging the RTC’s order for execution pending appeal. The COMELEC issued a resolution setting aside the RTC’s order, thereby suspending the execution and preventing Pioquinto from assuming office until the appeal was resolved. Camilian then filed this petition, arguing that the COMELEC committed grave abuse of discretion in reversing the trial court’s order.

ISSUE

Whether the Commission on Elections committed grave abuse of discretion in setting aside the Regional Trial Court’s order for execution pending appeal.

RULING

The Supreme Court, through the main decision concurred with by Justice Vitug, dismissed the petition and upheld the COMELEC’s resolution. The legal logic centers on the scope of the COMELEC’s appellate authority and the requisites for execution pending appeal under the Omnibus Election Code. Execution pending appeal is an exceptional remedy, not a matter of right, and must be based on good reasons stated in a special order.
The Court ruled that the COMELEC did not abuse its discretion in finding the RTC’s justifications for immediate execution to be inadequate. The determination of what constitutes “good reasons” under Section 2, Rule 39 of the Rules of Court, as applied in election cases, is subject to the COMELEC’s review. As the constitutional body vested with exclusive authority to decide all election contests involving municipal officials, the COMELEC has the supervisory power to correct any capricious, arbitrary, or whimsical exercise of discretion by the trial court. Its finding that the reasons proffered by the RTC did not warrant a departure from the general rule that execution should await final judgment was a valid exercise of its adjudicative power, not an abuse thereof.