This Supreme Court case clarifies when the House of Representatives Electoral Tribunal (HRET) gains jurisdiction over election disputes. Once a candidate for the House of Representatives is proclaimed the winner, takes their oath, and assumes office, the HRET’s jurisdiction begins, and the Commission on Elections’ (COMELEC) jurisdiction ends. This ensures that challenges to congressional elections are resolved by the body specifically designated for that purpose.

From Election Dispute to HRET Authority: When Does COMELEC’s Role End?

This case revolves around a dispute for the position of Representative of the 1st Congressional District of Lanao del Norte during the 2007 elections. Imelda Dimaporo and Vicente Belmonte were the contending candidates. After the election, questions arose regarding the integrity of the Certificates of Canvass (COCs) from several municipalities. Belmonte alleged that there were manifest errors and tampering in the COCs, leading him to file a petition with the COMELEC for correction of these errors.

The COMELEC initially took cognizance of the petition, treating it as a case for the correction of manifest errors, which falls under its jurisdiction according to Section 15 of R.A. No. 7166. This law allows canvassing bodies to correct manifest errors in certificates of canvass or election returns, either on their own initiative (motu proprio) or upon written complaint. The COMELEC Second Division granted Belmonte’s petition, ordering the exclusion of the questioned COCs and directing the Board of Canvassers to issue a new certificate of canvass.

However, before the COMELEC’s decision could be fully implemented, Belmonte was proclaimed the winner, took his oath of office, and assumed his duties as a Member of the House of Representatives. This development shifted the legal landscape of the case. According to the Supreme Court, once a winning candidate has been proclaimed, taken their oath, and assumed office, the HRET gains sole and exclusive jurisdiction over any contests related to their election, returns, and qualifications. The Court emphasized that allowing the COMELEC to continue hearing the case after Belmonte’s proclamation would usurp the HRET’s function.

The Supreme Court based its decision on the constitutional mandate that the HRET has the sole power to judge all contests relating to the election, returns, and qualifications of members of the House of Representatives. Several precedents support this view, including Lazatin v. Commission on Elections and Aggabao v. Commission on Elections. These cases affirm that the HRET’s jurisdiction begins the moment the winning candidate is proclaimed, takes their oath, and assumes office.

The HRET has sole and exclusive jurisdiction overall contests relative to the election, returns, and qualifications of members of the House of Representatives. Thus, once a winning candidate has been proclaimed, taken his oath, and assumed office as a Member of the House of Representatives, COMELEC’s jurisdiction over election contests relating to his election, returns, and qualifications ends, and the HRET’s own jurisdiction begins. – Aggabao v. Commission on Elections

The Court also underscored the importance of resolving election cases swiftly, consistent with the law’s desire to minimize delays in canvassing and proclamation. While the COMELEC acted promptly in deciding Belmonte’s petition, the subsequent events, particularly his proclamation and assumption of office, triggered the transfer of jurisdiction to the HRET. Therefore, any further challenge by Dimaporo regarding the election results should be pursued through an election protest filed before the HRET.

Ultimately, the Supreme Court dismissed Dimaporo’s petition, affirming that the HRET is the proper forum to resolve the election dispute, given Belmonte’s proclamation and assumption of office. This ruling reinforces the principle of respecting the constitutionally defined roles of electoral bodies and ensures that election contests are heard by the appropriate tribunal.

FAQs

What was the key issue in this case?	The central issue was whether the COMELEC retained jurisdiction over an election dispute for a congressional seat after the winning candidate had been proclaimed, taken their oath, and assumed office, or whether jurisdiction had shifted to the HRET.
When does the HRET gain jurisdiction over a congressional election contest?	The HRET gains jurisdiction once the winning candidate has been proclaimed, taken their oath, and assumed office as a Member of the House of Representatives. This marks the end of COMELEC’s jurisdiction over the matter.
What happens to pending cases before the COMELEC once the HRET gains jurisdiction?	Once the HRET gains jurisdiction, any pending election contests before the COMELEC related to the election, returns, and qualifications of the proclaimed candidate are effectively transferred to the HRET’s authority.
What should a candidate do if they wish to challenge election results after the proclamation of a winner?	If a candidate wishes to challenge the election results after the proclamation of a winner who has assumed office, they should file an election protest before the HRET, which is the proper forum for resolving such disputes.
What is the basis for the HRET’s jurisdiction over congressional election contests?	The HRET’s jurisdiction is based on the constitutional mandate that it has the sole power to judge all contests relating to the election, returns, and qualifications of members of the House of Representatives.
Can the COMELEC continue to hear election cases related to congressional seats after the winner is proclaimed?	No, the COMELEC’s jurisdiction ends once the winning candidate is proclaimed, takes their oath, and assumes office. Continuing to hear the case would usurp the function of the House Electoral Tribunal.
What if there was a Status Quo Ante Order when proclamation happened?	Considering that at the time of Belmonte’s proclamation, there had yet been no status quo ante order or temporary restraining order from the court, such proclamation is valid.
What does Section 15 of RA 7166 provide?	This section allows canvassing bodies to correct manifest errors in certificates of canvass or election returns, either on their own initiative (motu proprio) or upon written complaint.

This decision reinforces the principle of separation of powers and clarifies the respective roles of the COMELEC and the HRET in resolving election disputes. By delineating the point at which the HRET’s jurisdiction commences, the ruling provides a clear framework for candidates and electoral bodies alike.

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: IMELDA Q. DIMAPORO vs. COMMISSION ON ELECTIONS and VICENTE BELMONTE, G.R. No. 179285, February 11, 2008