G.R. No. 88158 and G.R. Nos. 97108-09, March 4, 1992
Daniel Garcia and Teodoro O’Hara vs. Ernesto De Jesus and Cecilia David, and the Commission on Elections; Tomas Tobon Uy vs. Commission on Elections and Jose C. Neyra

FACTS

These consolidated cases involve the jurisdiction of the Commission on Elections (COMELEC) to issue extraordinary writs. In G.R. No. 88158 (the Antipolo case), petitioners Garcia and O’Hara, proclaimed winners in the 1988 mayoral and vice-mayoral elections, were subjects of an election protest before the Regional Trial Court (RTC). The RTC issued an order limiting the ballot box examination to only nine of the twenty-five protested precincts. The protestees, De Jesus and David, filed a petition for certiorari and mandamus with the COMELEC, which then directed the RTC to open all ballot boxes. Petitioners Garcia and O’Hara objected, contending the COMELEC lacked jurisdiction to issue such writs.
In G.R. Nos. 97108-09 (the Isabela case), petitioner Tobon Uy was declared the winner by the RTC in an election protest for Mayor of Gamu, Isabela. The RTC granted his motion for execution pending appeal. The opposing candidate, Neyra, filed petitions for certiorari and/or prohibition with the COMELEC, which then issued a resolution nullifying the RTC’s order for execution pending appeal. Tobon Uy similarly challenged the COMELEC’s authority to issue these writs.

ISSUE

Whether the COMELEC has jurisdiction to issue writs of certiorari, prohibition, and mandamus in relation to election contests involving municipal officials decided by regional trial courts.

RULING

Yes, the COMELEC possesses the jurisdiction. The Court abandoned its previous ruling in Pimentel vs. COMELEC and held that the 1987 Constitution and pertinent laws grant the COMELEC such authority. Under Article IX-C, Section 2(2) of the Constitution, the COMELEC exercises “appellate jurisdiction over all contests involving elective municipal officials decided by trial courts of general jurisdiction.” This broad appellate power is complemented by Article IX-A, Section 6, which authorizes constitutional commissions like the COMELEC to “promulgate its own rules concerning pleadings and practice before it.”
To effectively exercise its appellate jurisdiction, the COMELEC must have the ancillary power to issue extraordinary writs. These writs are essential tools to correct acts of lower courts performed without or in excess of jurisdiction, or with grave abuse of discretion, which would otherwise frustrate the COMELEC’s appellate review. The Court emphasized that this power is inherent in and incidental to its constitutional mandate to decide election contests finally. The COMELEC’s exercise of this power in the cases at bar, to ensure the proper conduct of ballot examination and to prevent premature execution pending appeal, was a valid exercise of its jurisdiction to achieve a complete and efficacious resolution of the election disputes.