GR 158833; (May, 2004) (Digest)
G.R. No. 158833 ; May 12, 2004
DULCE ANN K. HOFER, petitioner, vs. HOUSE OF REPRESENTATIVES ELECTORAL TRIBUNAL and BELMA C. CABILAO, respondents.
FACTS
Petitioner Dulce Ann K. Hofer and respondent Belma A. Cabilao were candidates for the lone congressional district of Zamboanga Sibugay in the May 14, 2001 elections. Respondent was proclaimed the winner. Petitioner filed an election protest with the House of Representatives Electoral Tribunal (HRET), alleging massive irregularities in 671 precincts. After the revision of ballots from 481 pilot precincts, which resulted in a reduction of votes for both parties, the case proceeded to the reception of evidence.
During the preliminary conference, hearing dates were set from October to November 2002. Out of the seven scheduled hearing dates for the presentation of petitioner’s evidence, six were postponed at her instance. Only one hearing on October 29, 2002, proceeded. By February 2003, petitioner had not completed her evidence presentation.
ISSUE
Whether the HRET committed grave abuse of discretion in dismissing the election protest for petitioner’s failure to prosecute within the period allowed by its rules.
RULING
The Supreme Court ruled that the HRET did not commit grave abuse of discretion. The legal logic centers on the mandatory and expeditious nature of procedural rules in election cases. HRET Rule 59 explicitly allocates each party a period of twenty working days to complete the presentation of evidence, which may be extended for ten days only upon meritorious grounds. This period is charged not only for actual hearing days but also for delays caused by postponements requested by the presenting party.
Petitioner failed to comply with this rule. By causing the postponement of six out of seven hearing dates over more than six months, she exhausted her allotted period and demonstrated a lack of interest in prosecuting her case. The Court emphasized that while the will of the electorate is paramount, election protests are serious proceedings that demand strict adherence to procedural timelines to ensure their speedy resolution. The delay caused by petitioner’s inaction frustrates this objective. Therefore, the dismissal of the protest was a proper exercise of the HRET’s discretion to enforce its rules and prevent undue delay. The petition was dismissed.