G.R. No. 94521 and G.R. No. 94626, October 28, 1991
Oliver O. Lozano, petitioner, vs. Hon. Commissioner Haydee B. Yorac of the Commission on Elections, et al., respondents.

FACTS

Petitioner Oliver Lozano filed a petition for disqualification and a criminal complaint for vote-buying against then mayoral candidate Jejomar Binay before the 1988 local elections, alleging misuse of municipal funds. The case was assigned to the COMELEC Second Division, presided by Commissioner Haydee Yorac. Lozano filed multiple motions for Yorac’s inhibition, arguing bias because she had issued a memorandum opining that a conviction for vote-buying in regular courts was necessary before disqualification. All motions were denied.
The COMELEC en banc eventually dismissed the disqualification petition and criminal complaint against Binay. Lozano then filed two petitions before the Supreme Court: one ( G.R. No. 94521 ) challenging Yorac’s order denying inhibition, and another (G.R. No. 94626) seeking reversal of the COMELEC resolutions dismissing his case against Binay.

ISSUE

The primary issue is whether the Supreme Court can review the COMELEC’s factual findings and orders in a disqualification case, and whether Commissioner Yorac committed grave abuse of discretion warranting inhibition.

RULING

The Supreme Court dismissed the petitions and affirmed the COMELEC’s resolutions. On the issue of inhibition, the Court held that a claim of bias must be substantiated by clear and convincing evidence. Commissioner Yorac’s memorandum expressing a legal opinion on the procedural relationship between criminal conviction and administrative disqualification did not prove partiality or prejudice; it was a discharge of her official duty. Voluntary inhibition is discretionary, and no grave abuse of discretion was found in her refusal to recuse herself.
On the substantive challenge to the COMELEC’s dismissal of the case, the Court emphasized the constitutional principle of judicial non-interference in COMELEC’s exercise of its quasi-judicial powers. The COMELEC, as the specialized body tasked with adjudicating election contests and disqualification cases, possesses exclusive jurisdiction to evaluate evidence and determine facts. The Supreme Court’s power of review is limited to instances of grave abuse of discretion amounting to lack or excess of jurisdiction. Petitioner’s plea for the Court to re-examine the evidence constituted a request to revisit factual findings, which is prohibited. The alleged malversation of funds was properly dismissed and should be litigated in the appropriate regular courts.