GR 137004; (July, 2000) (Digest)
G.R. No. 137004 July 26, 2000
ARNOLD V. GUERRERO, petitioner, vs. THE COMMISSION ON ELECTIONS, HON. MANUEL B. VILLAR, JR., as the Speaker of the House of Representatives, 11th Congress, HON. ROBERTO P. NAZARENO, as the Secretary General of the House of Representatives, 11th Congress, RODOLFO C. FARIÑAS and GUILLERMO R. RUIZ, respondents.
FACTS
Guillermo Ruiz filed a petition before the COMELEC to disqualify Rodolfo Fariñas as a candidate for Congressman in Ilocos Norte’s first district for the May 11, 1998 elections. Ruiz alleged Fariñas was campaigning without having filed a Certificate of Candidacy (CoC) by the deadline, violating election laws. On May 8, 1998, Fariñas filed a CoC as a substitute for Chevylle V. Fariñas, who had withdrawn. The COMELEC Second Division dismissed Ruiz’s petition on May 10, 1998, reasoning that without a CoC on record, there was no candidate to disqualify. Fariñas won the election and was proclaimed.
Subsequently, petitioner Arnold Guerrero, the Liberal Party candidate, filed a petition-in-intervention. He argued Fariñas’s substitution was invalid because the original candidate was independent, and substitution is only allowed for a candidate of a registered political party. Guerrero sought Fariñas’s disqualification, a declaration of vacancy, and a special election. The COMELEC En Banc dismissed both the motion for reconsideration and the petition-in-intervention, stating it lacked jurisdiction and that the proper remedy was a quo warranto proceeding.
ISSUE
Whether the COMELEC committed grave abuse of discretion in dismissing the petitions and declining to rule on the validity of Fariñas’s candidacy and CoC.
RULING
The Supreme Court dismissed the petition, ruling the COMELEC did not commit grave abuse of discretion. The legal logic hinges on the doctrine of jurisdiction over election contests. Under the Constitution, the House of Representatives Electoral Tribunal (HRET) is the sole judge of all contests relating to the election, returns, and qualifications of its members. This jurisdiction begins upon a candidate’s proclamation as winner and assumption of office.
Fariñas was proclaimed winner and took his oath of office on June 3, 1998. From that point, any question pertaining to his eligibility for the office, including the validity of his CoC and substitution, fell under the exclusive jurisdiction of the HRET. The COMELEC’s jurisdiction over disqualification cases is limited to candidates before proclamation. Once a candidate is proclaimed and assumes office, the COMELEC correctly loses jurisdiction. Its directive for the aggrieved party to file a quo warranto case with the HRET was proper. The Court found no grave abuse of discretion, as the COMELEC acted in accordance with the clear jurisdictional delineation established by law.