G.R. No. L-19260; January 31, 1962
DELFIN ALBANO, petitioner, vs. HON. MANUEL ARRANZ, as Judge of the Court of First Instance of Isabela, Branch I, and SAMUEL REYES, respondents.

FACTS

In the November 1961 elections, petitioner Delfin Albano and respondent Samuel Reyes were candidates for Representative of Isabela. During the provincial canvass, Albano’s representative questioned the returns from several precincts in Cabagan and Reina Mercedes, alleging erasures and discrepancies between the copies furnished to the Nacionalista Party and those held by the Provincial Treasurer, to Albano’s detriment. The Commission on Elections (COMELEC), informed of the controversy, issued a telegraphic order on December 6, 1961, directing the Provincial Board of Canvassers to suspend the proclamation of the winning candidate pending further orders. The board complied, suspending the canvass of the disputed returns.
Respondent Samuel Reyes subsequently filed a petition for mandamus in the Court of First Instance (CFI) of Isabela, presided over by respondent Judge Manuel Arranz, seeking to compel the Board of Canvassers to canvass the disputed votes and proclaim a winner. He argued the COMELEC’s suspension orders were null and void. The respondent judge set the case for hearing and issued a preliminary injunction to prevent the board from sending the questioned returns to Manila as instructed by COMELEC.

ISSUE

Whether the Court of First Instance had jurisdiction to entertain the mandamus petition and to issue an injunction against the implementation of the COMELEC’s suspension order.

RULING

The Supreme Court ruled that the CFI acted without jurisdiction. The COMELEC’s order to suspend the proclamation was a valid exercise of its constitutional and administrative authority to enforce election laws. Its power to inquire into alleged irregularities, such as discrepancies between election return copies, and to order a suspension of the canvass to allow for a potential recount, is exclusive.
Critically, the Constitution expressly provides that COMELEC decisions, orders, and rulings are subject to review only by the Supreme Court, not by any other tribunal. Therefore, the CFI had no authority to pass upon the validity of the COMELEC’s order, especially without the COMELEC being impleaded as a party. To allow regional trial courts to countermand or interfere with COMELEC orders would lead to chaos and effectively nullify the COMELEC’s constitutional mandate. The writ of prohibition was granted, and the respondent court was ordered to permanently desist from proceeding with the mandamus case.