The Supreme Court in Vito Beso v. Rita Aballe clarified that Regional Trial Courts (RTC) lack jurisdiction over petitions questioning the execution of decisions in barangay election protests when the Commission on Elections (COMELEC) already has appellate jurisdiction. This ruling underscores the importance of adhering to the hierarchical structure of election dispute resolution, ensuring that the COMELEC’s exclusive authority in appellate matters is respected and upheld, thereby safeguarding the integrity of electoral processes at the barangay level.

Navigating the Legal Maze: Who Decides Barangay Election Disputes?

The case of Vito Beso v. Rita Aballe arose from a contested barangay election in Calbayog City. Vito Beso and Rita Aballe were candidates for Barangay Captain. After the election, Aballe was proclaimed the winner by a narrow margin. Beso then filed an election protest with the Municipal Trial Court of Calbayog City (MTCC), which ruled in his favor. Aballe appealed this decision, filing a Notice of Appeal indicating that she was appealing to the Commission on Elections (COMELEC), while simultaneously appealing to the Regional Trial Court. Complicating matters further, Beso sought execution of the MTCC’s decision pending appeal, which the MTCC granted.

Aballe, contending that the MTCC had lost jurisdiction, then filed a special civil action for certiorari and prohibition with the Regional Trial Court (RTC) to annul the MTCC’s orders. The RTC sided with Aballe, setting aside the MTCC’s writ of execution. This prompted Beso to elevate the issue to the Supreme Court, questioning the RTC’s jurisdiction to entertain Aballe’s petition given the pending appeal before the COMELEC. This case turns on the critical question of which court or body has the authority to resolve disputes arising during the appeal of a barangay election protest.

The Supreme Court addressed the central issue of jurisdiction, emphasizing the exclusive appellate jurisdiction of the COMELEC in barangay election contests. Building on this principle, the Court referenced Section 2, Article IX-C of the Constitution, which explicitly grants the COMELEC exclusive appellate jurisdiction over contests involving elective barangay officials decided by trial courts of limited jurisdiction. The Court reinforced this constitutional provision with the ruling in Relampagos v. Cumba, et al., stating that the COMELEC possesses the authority to issue extraordinary writs like certiorari and prohibition in aid of its appellate jurisdiction, particularly in cases where it has exclusive appellate authority.

The Court quoted the critical provision from Section 50 of B.P. Blg. 697, which explicitly vests the COMELEC with exclusive authority to hear and decide petitions for certiorari, prohibition, and mandamus involving election cases:

“The Commission is hereby vested with exclusive authority to hear and decide petitions for certiorari, prohibition and mandamus involving election cases.”

The Supreme Court found that the RTC acted without jurisdiction when it entertained Aballe’s petition for certiorari and prohibition. According to the Court, because Aballe had already filed an appeal with the COMELEC, the COMELEC held primary jurisdiction to resolve any issues related to the execution pending appeal granted by the MTCC. This position aligns with the established principle that when an appeal is perfected, the appellate court assumes jurisdiction over the case, including all related incidents. The RTC’s intervention, therefore, constituted an overreach of its authority and a violation of the hierarchical structure established for election dispute resolution.

The Court also addressed Aballe’s argument that it was impractical for her to seek relief from the COMELEC because the records of the election protest were not immediately available. The Court dismissed this argument, noting that Aballe could have easily obtained certified copies of the challenged resolutions or orders and attached them to her petition. This underscores the importance of due diligence and the availability of alternative means to comply with procedural requirements. The Court further pointed out the RTC’s error in extending the temporary restraining order (TRO) beyond the permissible period. Citing Section 5 of Rule 5 of the 1997 Rules of Civil Procedure, the Court emphasized that the total period of effectivity of a TRO, including the original seventy-two hours, should not exceed twenty days.

The Supreme Court’s ruling serves to reinforce the principle of hierarchical jurisdiction, especially in election cases. The decision underscores the importance of adhering to the designated channels for resolving election disputes, ensuring that the COMELEC’s role as the primary appellate body is not undermined by unwarranted interventions from lower courts. By clarifying the jurisdictional boundaries between the RTC and the COMELEC in barangay election protests, the Court safeguards the integrity and efficiency of the electoral process.

Below is a summary table showing the jurisdictional errors committed by the RTC:

Error	Legal Basis
Entertaining a petition for certiorari when the COMELEC had appellate jurisdiction	Section 2, Article IX-C of the Constitution and jurisprudence
Extending the temporary restraining order beyond the permissible period	Section 5 of Rule 5 of the 1997 Rules of Civil Procedure

FAQs

What was the key issue in this case?	The central issue was whether the Regional Trial Court (RTC) had jurisdiction to hear a petition for certiorari related to an election protest when the Commission on Elections (COMELEC) already had appellate jurisdiction over the case.
What is the role of the COMELEC in barangay election disputes?	The COMELEC has exclusive appellate jurisdiction over contests involving elective barangay officials decided by trial courts of limited jurisdiction, as provided under Section 2 of Article IX-C of the Constitution.
What extraordinary writs can the COMELEC issue?	In aid of its appellate jurisdiction, the COMELEC can issue extraordinary writs of certiorari, prohibition, and mandamus in cases where it has exclusive appellate authority.
What was the basis for the Supreme Court’s decision?	The Supreme Court based its decision on the constitutional and statutory provisions granting the COMELEC exclusive appellate jurisdiction, and on the established principle of hierarchical jurisdiction.
Why did the Supreme Court say the RTC acted without jurisdiction?	The Supreme Court held that because the COMELEC already had appellate jurisdiction due to the pending appeal, the RTC’s intervention constituted an overreach of its authority.
What was wrong with the RTC’s temporary restraining order?	The RTC erred by extending the temporary restraining order beyond the maximum permissible period of twenty days, including the initial seventy-two hours.
What happens when the RTC oversteps its jurisdictional boundaries?	When the RTC oversteps its jurisdictional boundaries, its actions are considered null and void for lack of jurisdiction, and the Supreme Court may set aside and nullify the orders.
What is the practical implication of this ruling?	The practical implication is that parties involved in barangay election disputes must adhere to the designated channels for resolving such disputes, ensuring that the COMELEC’s role as the primary appellate body is respected.

In conclusion, the Supreme Court’s decision in Vito Beso v. Rita Aballe serves as a crucial reminder of the importance of respecting jurisdictional boundaries in election dispute resolution. By reaffirming the COMELEC’s exclusive appellate authority, the Court reinforces the integrity of the electoral process and ensures that disputes are resolved through the appropriate channels.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: VITO BESO VS. RITA ABALLE, G.R. No. 134932, February 18, 2000