GR 97710; (September, 1991) (Digest)
G.R. No. 97710 September 26, 1991
DR. EMIGDIO A. BONDOC, petitioner, vs. REPRESENTATIVES MARCIANO M. PINEDA, MAGDALENO M. PALACOL, COL. JUANITO G. CAMASURA, JR., or any other representative who may be appointed vice representative Juanita G. Camasura, Jr., and THE HOUSE OF REPRESENTATIVES ELECTORAL TRIBUNAL, respondents.
FACTS
Petitioner Emigdio Bondoc and respondent Marciano Pineda were rival candidates for Representative of Pampanga’s Fourth District in the 1987 elections. Pineda was proclaimed winner. Bondoc filed an election protest before the House of Representatives Electoral Tribunal (HRET). After revision and appreciation of ballots, the HRET reached a decision wherein Bondoc won by a margin of 23 votes. The HRET was composed of nine members: three Supreme Court Justices and six House members based on proportional representation from political parties therein.
During the finalization of this decision, the dominant political party in the House, the Laban ng Demokratikong Pilipino (LDP), sought to change its representation in the HRET. The House, upon the LDP’s request, adopted a resolution withdrawing the party membership of Congressman Juanito Camasura from the LDP and replacing him with Congressman Magdaleno Palacol in the HRET. Camasura had voted in favor of Bondoc in the tribunal’s deliberations. This change in HRET membership altered the tribunal’s composition and potentially the outcome of the pending case.
ISSUE
May the Supreme Court review and annul the act of the House of Representatives in changing its party’s representation in the House Electoral Tribunal to affect the outcome of a pending election contest?
RULING
Yes. The Supreme Court ruled that the act of the House of Representatives is subject to judicial review. The Court emphasized that while it traditionally avoids political questions, it has the constitutional duty to determine whether any branch or instrumentality of the Government has committed a grave abuse of discretion amounting to lack or excess of jurisdiction. The 1987 Constitution expressly grants the judiciary this power.
The legal logic is that the constitutional grant of authority to the House to choose its members in the HRET is not without limitation. The power must be exercised in accordance with the Constitution and cannot be used to undermine the tribunal’s independence and judicial function. By changing its representation in the HRET to thwart the promulgation of a decision already reached in a pending case, the House committed a grave abuse of discretion. It effectively interfered with the tribunal’s duty to be an impartial arbiter of election contests, which requires stability in its membership during the pendency of a case to ensure due process. The act was a clear manipulation to reverse a judicial outcome, violating the constitutional principle of separation of powers and the HRET’s independence as a constitutional body. Consequently, the Court annulled the House resolution and ordered the reinstatement of Congressman Camasura to the HRET to complete the promulgation of the decision in the election protest.