GR 204123; (March, 2013) (Digest)
G.R. No. 204123 ; March 19, 2013
MARIA LOURDES B. LOCSIN, Petitioner, vs. HOUSE OF REPRESENTATIVES ELECTORAL TRIBUNAL and MONIQUE YAZMIN MARIA Q. LAGDAMEO, Respondents.
FACTS
Petitioner Maria Lourdes B. Locsin and private respondent Monique Yazmin Maria Q. Lagdameo were candidates for Representative of Makati City’s First District in the May 2010 elections. Lagdameo was proclaimed winner with 42,102 votes against Locsin’s 41,860, a margin of 242 votes. Locsin filed an election protest before the House of Representatives Electoral Tribunal (HRET), alleging fraud and irregularities in all 233 clustered precincts. Lagdameo filed a counter-protest covering 123 precincts. After revision and appreciation of ballots from the pilot protested precincts, Lagdameo’s lead increased to 265 votes. The HRET, by Resolution, continued proceedings for the remaining precincts, after which the lead further increased to 335 votes. The HRET dismissed Locsin’s protest for failure to show a reasonable recovery of votes.
ISSUE
Whether the HRET committed grave abuse of discretion in dismissing Locsin’s election protest.
RULING
The Supreme Court dismissed the petition, finding no grave abuse of discretion by the HRET. The Court emphasized that under the Constitution, the HRET is the sole judge of all contests relating to the election, returns, and qualifications of members of the House of Representatives. Judicial review of HRET decisions is limited to instances of grave abuse of discretion amounting to lack or excess of jurisdiction. Grave abuse of discretion implies a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction.
The Court found that the HRET acted within its constitutional mandate. Its detailed appreciation of contested ballots, governed by election laws and jurisprudence, was a legitimate exercise of its adjudicative power. The HRET’s factual findings—including its determinations on the validity of marked ballots and the shading threshold for ballots—are beyond this Court’s review, absent a clear showing of arbitrariness. Locsin’s arguments essentially questioned the HRET’s factual assessments and application of rules on ballot appreciation, which do not constitute grave abuse of discretion. The HRET’s decision was grounded on evidence and legal principles, and its continuation of proceedings beyond the pilot precincts demonstrated diligence, not arbitrariness. Thus, no jurisdictional error warranting certiorari was present.