G.R. No. 97105 October 15, 1991
Rosette Yniguez Lerias, petitioner, vs. House of Representatives Electoral Tribunal and Roger G. Mercado, respondents.

FACTS

Petitioner Rosette Y. Lerias and private respondent Roger G. Mercado were candidates for Representative of Southern Leyte in the 1987 elections. The initial canvass showed a close race. The certificate of canvass from Libagon was critical. The Provincial Board of Canvassers rejected its own copy due to alleged erasures, using instead the Comelec copy, which credited Lerias with 400 fewer votes in four precincts. This resulted in Mercado’s proclamation by a margin of 254 votes. Lerias challenged this before the Comelec, seeking a recount, but her petitions were dismissed. She then filed an election protest with the House of Representatives Electoral Tribunal (HRET).
The HRET, after proceedings, dismissed Lerias’s protest. It found the Comelec copy of the Libagon certificate to be authentic and ruled that the entries in the Provincial Board’s copy were altered. It held that the best evidence of the votes were the election returns, not the certificate of canvass, and that Lerias failed to substantiate her claim of tampering. Lerias elevated the case to the Supreme Court via certiorari, alleging the HRET committed grave abuse of discretion in its appreciation of evidence.

ISSUE

Whether the House of Representatives Electoral Tribunal committed grave abuse of discretion in dismissing the election protest.

RULING

The Supreme Court dismissed the petition, upholding the HRET’s decision. The legal logic rests on the constitutional mandate and the limited scope of judicial review over electoral tribunal decisions. Under Article VI, Section 17 of the 1987 Constitution, the HRET is the sole judge of all contests relating to the election, returns, and qualifications of its members. This Court’s power of review is extraordinary and may be exercised only upon a clear showing that the tribunal acted without or in excess of jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction.
The Court found no such grave abuse. The HRET’s findings—on the authenticity of the Comelec copy, the alterations in the Provincial Board’s copy, and the failure of the protestant to present convincing proof—were conclusions derived from its evaluation of the evidence. The appreciation of evidence is within the exclusive domain of the HRET as the sole judge of such facts. An error in judgment, if any, is not equivalent to grave abuse of discretion. Grave abuse of discretion implies a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction. The petitioner’s arguments essentially sought a re-evaluation of the evidence, which the Court cannot undertake without transgressing the constitutional boundary separating its authority from that of the HRET. The petition merely demonstrated a disagreement with the HRET’s factual conclusions, not a jurisdictional flaw.