G.R. No. 134792, August 12, 1999
PERLA GARCIA, PAZ CRUZ and GERALDINE PADERNAL, petitioners, vs. THE HOUSE OF REPRESENTATIVES ELECTORAL TRIBUNAL (HRET) and REP. HARRY ANGPING (3rd DISTRICT MANILA), respondents.

FACTS

On May 29, 1998, within the prescribed ten-day period, petitioners, who are duly registered voters, filed a petition for quo warranto before the House of Representatives Electoral Tribunal (HRET) against Congressman Harry Angping. They questioned his eligibility to hold office, claiming he was not a natural-born citizen of the Philippines. Upon filing, petitioners paid the required P5,000.00 filing fee. On June 10, 1998, the HRET issued a Resolution dismissing the petition for failure to pay the P5,000.00 cash deposit required by its Rules. After receiving a copy of the Resolution, petitioners paid the P5,000.00 cash deposit on June 26, 1998 and attached the receipt to a Motion for Reconsideration filed the same day. The HRET denied the motion, citing Rule 32 of the 1998 HRET Rules which required the cash deposit in addition to filing fees. Petitioners filed the instant Petition for Certiorari, arguing the HRET committed grave abuse of discretion by dismissing the petition on a mere technicality despite subsequent payment and by strictly construing its Rules against the enjoined liberal construction.

ISSUE

Whether the HRET committed grave abuse of discretion in summarily dismissing the petition for quo warranto for failure to pay the required cash deposit and in refusing to reinstate it after petitioners rectified the payment.

RULING

No, the HRET did not commit grave abuse of discretion. The Supreme Court held that while it may inquire into acts of the HRET for grave abuse of discretion under its expanded judicial power, no such abuse was present in this case. Rule 32 of the 1998 HRET Rules clearly requires a P5,000.00 cash deposit for quo warranto petitions in addition to filing fees. Rule 21 explicitly allows for the summary dismissal of a petition for quo warranto if, inter alia, the cash deposit is not paid within ten days after the filing of the protest or petition. The Court found the HRET’s dismissal was based on a clear and mandatory provision of its Rules. The subsequent payment and motion for reconsideration did not cure the initial non-compliance, as the rules do not provide for a grace period. The HRET’s strict application of its procedural rules was not a denial of due process, as procedural rules are necessary for the orderly administration of justice. The Court emphasized that the HRET is the sole judge of contests relating to the elections, returns, and qualifications of its members, and its acts, when within its jurisdiction, are generally beyond judicial interference. The petition for certiorari was dismissed.