GR L 62075; (April, 1987) (Digest)
G.R. No. L-62075 April 15, 1987
NATIVIDAD CORPUS, AURORA FONBUENA, JOSIE PERALTA, CRESENCIA PADUA, DOMINADOR BAUTISTA, LEOLA NEOG, EPIFANIO CASTILLEJOS AND EDGAR CASTILLEJOS, petitioners, vs. TANODBAYAN OF THE PHILIPPINES, FISCAL JUAN L. VILLANUEVA, JR., AND ESTEBAN MANGASER, respondents.
FACTS
Petitioners were members of a Citizens Election Committee, a Bureau of Domestic Trade Director, and an elected mayor in Caba, La Union. Private respondent Esteban Mangaser, a candidate for vice-mayor, charged them with electioneering inside voting centers during the January 30, 1980 elections. The complaint was initially filed with the Commission on Elections (COMELEC). After a formal investigation, the COMELEC’s Regional Election Director recommended dismissal. Mangaser then withdrew his COMELEC complaint and refiled identical charges with the Tanodbayan.
The COMELEC subsequently dismissed the complaint for insufficiency of evidence. Nevertheless, the Tanodbayan, through an assistant provincial fiscal, commenced a preliminary investigation on the refiled complaint. The COMELEC Legal Assistance Office moved for dismissal, arguing the case fell under COMELEC jurisdiction, but the Tanodbayan denied the motion. The Tanodbayan asserted its exclusive authority to prosecute public officers for offenses committed in relation to their office, contending COMELEC lawyers lacked authority unless deputized as Tanodbayan prosecutors.
ISSUE
Whether the Tanodbayan has jurisdiction to investigate and prosecute election offenses allegedly committed by public officers in relation to their office, or if such jurisdiction resides exclusively with the COMELEC.
RULING
The Supreme Court granted the petition, ruling that exclusive jurisdiction over election offenses rests with the COMELEC, regardless of whether the offender is a public officer. The Court anchored its decision on the constitutional mandate granting the COMELEC the power to enforce and administer all laws relative to the conduct of elections. This includes the concomitant authority to investigate and prosecute election offenses, a power essential to ensuring free, orderly, and honest elections.
The Court, citing the precedent in De Jesus v. People, rejected the Tanodbayan’s claim of exclusive authority. It clarified that jurisdiction is determined by the nature of the offense—an election offense—and not by the personality of the offender as a public officer. The constitutional and statutory grant of authority to the COMELEC is clear and categorical, covering offenses committed by any person. To divest the COMELEC of jurisdiction over election offenses involving public officers would seriously impair its constitutional duty to safeguard the electoral process. Consequently, the Tanodbayan’s reinvestigation of the charges, already dismissed by the COMELEC, was void. The complaint was ordered dismissed.