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458 SUPREME COURT REPORTS ANNOTATED

Guerrero vs. Commission on Elections

*
G.R. No. 137004. July 26, 2000.

ARNOLD V. GUERRERO, petitioner, vs. THE

COMMISSION ON ELECTIONS, HON. MANUEL B.
VILLAR, JR., as the Speaker of the House of
Representatives, 11th Congress, HON. ROBERTO P.
NAZARENO, as the Secretary General of the House of
Representatives, 11th Congress, RODOLFO C. FARIÑAS
and GUILLERMO R. RUIZ, respondents.

Election Law; Actions; Certiorari; Pleadings and Practice; A

special civil action for certiorari is the proper remedy to question
any final order, ruling and decision of the COMELEC rendered in
the exercise of its adjudicatory or quasi-judicial powers.—A special
civil action for certiorari may be availed of when the tribunal,
board, or officer exercising judicial or quasi-judicial functions has
acted without or in excess of jurisdiction and there is no appeal or
any plain, speedy, and adequate remedy in the ordinary course of
law for the purpose of annulling the proceeding. It is the proper
remedy to question any final order, ruling and decision of the
COMELEC rendered in the exercise of its adjudicatory or quasi-
judicial powers. But for an action for certiorari to prosper, there
must be a showing that the COMELEC acted with grave abuse of
discretion. This means such capricious and whimsical exercise of
judgment as is equivalent to lack of jurisdiction or excess thereof,
as where the power is exercised in an arbitrary and despotic
manner by reason of passion or personal hostility, and it must be
so patent as to amount to an evasion of positive duty or a virtual
refusal to perform the duty enjoined by law.
Same; House of Representatives Electoral Tribunal (HRET);
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.—In the present case, we find no grave abuse
of discretion on the part of the COMELEC when it held that its
jurisdiction over Case No. SPA 98-277 had ceased with the

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assumption of office of respondent Fariñas as Representative for

the first district of Ilocos Norte. While the COMELEC is vested
with the power to declare valid or invalid a certificate of
candidacy, its refusal to exercise that power following the
proclamation and assumption of the position by Fariñas is a
recognition of the jurisdictional boundaries separating the
COMELEC and the Electoral Tribunal of the House of
Representatives

_______________

* EN BANC.

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VOL. 336, JULY 26, 2000 459

Guerrero vs. Commission on Elections

(HRET). Under Article VI, Section 17 of the Constitution, the

HRET has sole and exclusive jurisdiction over all 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 HRETs own jurisdiction begins. Thus,
the COMELEC’s decision to discontinue exercising jurisdiction
over the case is justifiable, in deference to the HRETs own
jurisdiction and functions.
Same; Same; Statutory Construction; Article VI, Section 17 of
the Constitution cannot be circumscribed lexically—the word
“qualifications” cannot be read as qualified by the term
“constitutional”; Basic is the rule in statutory construction that
where the law does not distinguish, the courts should not
distinguish.—Petitioner contends that the jurisdiction of the
HRET as defined under Article VI, Section 17 of the Constitution
is limited only to the qualifications prescribed under Article VI,
Section 6 of the Constitution. Consequently, he claims that any
issue which does not involve these constitutional qualifications is
beyond the realm of the HRET. The filing of a certificate of
candidacy being a statutory qualification under the Omnibus
Election Code is outside the pale of the HRET, according to him.
This contention lacks cogency and is far from persuasive. Article
VI, Section 17 of the Constitution cannot be circumscribed

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lexically. The word “qualifications” cannot be read as qualified by

the term “constitutional.” Ubi lex non distinguit noc nos
distinguire debemos. Basic is the rule in statutory construction
that where the law does not distinguish, the courts should not
distinguish. There should be no distinction in the application of a
law where none is indicated. For firstly, the drafters of the
fundamental law, in making no qualification in the use of a
general word or expression, must have intended no distinction at
all. Secondly, the courts could only distinguish where there are
facts or circumstances showing that the lawgiver intended a
distinction or qualification. In such a case, the courts would
merely give effect to the lawgiver’s intent.
Same; Same; In an electoral contest where the validity of the
proclamation of a winning candidate who has taken his oath of
office and assumed his post as Congressman is raised, that issue is
best addressed to the House of Representatives Electoral Tribunal.
—Petitioner further argues that the HRET assumes jurisdiction
only if there is a valid proclamation of the winning candidate. He
contends that if a candidate fails to satisfy the statutory
requirements to qualify him as a candidate, his subsequent
proclamation is void ab initio. Where the proclamation is null and
void, there is no proclamation at all and the mere assumption of
office by the

460

460 SUPREME COURT REPORTS ANNOTATED

Guerrero vs. Commission on Elections

proclaimed candidate does not deprive the COMELEC at all of its

power to declare such nullity, according to petitioner. But as we
already held, in an electoral contest where the validity of the
proclamation of a winning candidate who has taken his oath of
office and assumed his post as Congressman is raised, that issue
is best addressed to the HRET. The reason for this ruling is self-
evident, for it avoids duplicity of proceedings and a clash of
jurisdiction between constitutional bodies, with due regard to the
people’s mandate.
Same; Same; Whether a congressional candidate validly
substituted another candidate who withdrew and whether the
former became a legitimate candidate must likewise be addressed
to the sound judgment of the Electoral Tribunal.—Whether
respondent Fariñas validly substituted Chevylle V. Fariñas and
whether respondent became a legitimate candidate, in our view,
must likewise be addressed to the sound judgment of the Electoral

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Tribunal. Only thus can we demonstrate fealty to the

Constitutional provision that the Electoral Tribunal of each
House of Congress shall be the “sole judge of all contests relating
to the election, returns, and qualifications of their respective
members.”

SPECIAL CIVIL ACTION in the Supreme Court.

Certiorari, Prohibition and Mandamus.

The facts are stated in the opinion of the Court.

     Arnold V. Guerrero & Associates for petitioner.
     Mario M. Arzadon for respondent G. Ruiz.

QUISUMBING, J.:

Before the Court is a petition for certiorari, prohibition,

and mandamus, with prayer for a temporary restraining
order and/or preliminary injunction, under Rule 65 of the
Rules of Court. It assails the Order of the Commission on
Elections, Second Division, dated May 10, 1998, in
COMELEC Case No. SPA 98-227, which dismissed the
petition filed by herein respondent Guillermo C. Ruiz to
disqualify respondent Rodolfo C. Fariñas as a candidate for
the elective office of Congressman in the first district of
Ilocos Norte during the May 11, 1998 elections. It also
assails the Resolution dated May 16, 1998, of the
COMELEC En Banc, denying the motion for
reconsideration filed by respondent Ruiz and dismissing

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VOL. 336, JULY 26, 2000 461

Guerrero vs. Commission on Elections

the petition-in-intervention filed by herein petitioner

Arnold V. Guerrero.
In the Second Division of the COMELEC, Ruiz sought to
perpetually disqualify respondent 1
Fariñas as a candidate
for the position of Congressman. Ruiz alleged that Fariñas
had been campaigning as a candidate for Congressman in
the May 11, 1998 polls, despite his failure to file a
Certificate of Candidacy for said office. Ruiz averred that
Fariñas’ failure to file said Certificate
2
violated Section 73 of
the Omnibus Election Code in relation to COMELEC
Resolution No. 2577, dated January 15, 1998. Ruiz asked
the COMELEC to declare Fariñas as a “nuisance
candidate”
3
pursuant to Section 69 of the Omnibus Election
Code and to dis-

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_______________

1 Annex “C,” Rollo, pp. 51-58.

2 “SEC. 73. Certificate of candidacy.—No person shall be eligible for any
elective public office unless he files a sworn certificate of candidacy within
the period fixed herein.
“A person who has filed a certificate of candidacy may, prior to the
election, withdraw the same by submitting to the office concerned a
written declaration under oath.
“No person shall be eligible for more than one office to be filled in the
same election, and if he files his certificate of candidacy for more than one
office, he shall not be eligible for any of them. However, before the
expiration of the period for the filing of certificates of candidacy, the
person who has filed more than one certificate of candidacy may declare
under oath the office for which he desires to be eligible and cancel the
certificate of candidacy for the other office or offices.
“The filing or withdrawal of certificate of candidacy shall not affect
whatever civil, criminal or administrative liabilities which a candidate
may have incurred.”
3 “SEC. 69. Nuisance candidates.—The Commission may, motu proprio
or upon a verified petition of an interested party, refuse to give due course
to or cancel a certificate of candidacy, if it is shown that said certificate
has been filed to put the election process in mockery or disrepute or cause
confusion among the voters by the similarity of the names of the
registered candidates or by other circumstances or acts which clearly
demonstrate that the candidate has no bona fide intention to run for the
office for which the certificate of candidacy has been filed and thus
prevent a faithful determination of the true will of the electorate.”

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Guerrero vs. Commission on Elections

qualify him from running in the May 11, 1998 elections, as

well as in all future polls.
On May 8, 1998, Fariñas filed his Certificate of
Candidacy with the COMELEC, substituting candidate
Chevylle V. Fariñas who withdrew on April 3, 1998.
On May 9, 1998, Ruiz filed an “Urgent Ex-Parte Motion
To Resolve Petition” with the COMELEC, attaching thereto
a copy of the Certificate of Candidacy of Fariñas.
On May 10, 1998, the Second Division of the COMELEC
decided Case No. SPA 98-227, disposing as follows:

“WHEREFORE, premises considered, the Commission (Second

Division) RESOLVES to DISMISS the instant petition for utter
lack of merit.
4
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4
“SO ORDERED.”

In dismissing Ruiz’s petition, the Second Division of the

COMELEC stated, “[T]here is none (sic) in the records to
consider respondent an official candidate to speak of
without the filing of said certificate. Hence, there is no
certificate of candidacy to be 5
cancelled, consequently, no
candidate to be disqualified.”
On May 11, 1998, the elections pushed through as
scheduled. The post-election tally of votes in Ilocos Norte
showed that Fariñas got a total of 56,369 votes
representing the highest number of votes received in the
first district. Fariñas was duly proclaimed winner.
On May 16, 1998, Ruiz filed a motion for
reconsideration, contending that Fariñas could not validly
substitute for Chevylle V. Fariñas, since the latter was not
the official candidate of the Lakas ng Makabayan Masang
Pilipino (LAMMP), but was an independent candidate.
Another person cannot substitute for an independent
candidate. Thus, Fariñas’ certificate of candidacy claiming
to be the official candidate of LAMMP in lieu of Chevylle V.
Fariñas was fatally defective, according to Ruiz.
On June 3, 1998, Fariñas took his oath of office as a
member of the House of Representatives.

_______________

4 Supra Note 1, at 43.

5 Id. at 42-43.

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VOL. 336, JULY 26, 2000 463

Guerrero vs. Commission on Elections

On June 10, 1998, petitioner herein filed his “Petition-In-

Intervention” in COMELEC Case No. SPA 98-227.
Petitioner averred that he was the official candidate of the
Liberal Party (LP) in said elections for Congressman, and
stood to be adversely affected by Case No. SPA 98-227.
Guerrero contended that Fariñas, having failed to file his
Certificate of Candidacy on or before the last day therefor,
being midnight of March 27, 1998, Fariñas illegally
resorted to the remedy of substitution provided6
for under
Section 77 of the Omnibus Election Code and thus,
Fariñas’ disqualification was in order. Guerrero then asked
that the position of Representative of the first district of

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Ilocos Norte be declared vacant and special elections called

for, but disallowing the candidacy of Fariñas.
On January 6, 1999, the COMELEC En Banc dismissed
Ruiz’s motion for reconsideration and Guerrero’s petition-
in-intervention in Case No. SPA 98-227. The decretal
portion of its Resolution reads:

“PRESCINDING FROM THE FOREGOING PREMISES, this

Commission (En Banc) RESOLVED, as it hereby RESOLVES, to
AFFIRM the Order of the Commission (Second Division) and
thereafter, DISMISS this instant motion for reconsideration for
lack of jurisdiction (italics in the original) without prejudice to the
filing of a quo warranto case, if he so desires.

_______________

6 “SEC. 77. Candidates in case of death, disqualification or withdrawal of

another.—If after the last day for the filing of certificates of candidacy, an official
candidate of a registered or accredited political party dies, withdraws or is
disqualified for any cause, only a person belonging to and certified by, the same
political party may file a certificate of candidacy to replace the candidate who died,
withdrew or was disqualified. The substitute candidate nominated by the political
party concerned may file his certificate of candidacy for the office affected in
accordance with the preceding sections not later than mid-day of the day of the
election. If the death withdrawal or disqualification should occur between the day
before the election and mid-day of election day, said certificate may be filed with
any board of election inspectors in the political subdivision where he is a
candidate, or, in the case of candidates to be voted for by the entire electorate of
the country, with the Commission.”

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Guerrero vs. Commission on Elections
7
“SO ORDERED.”

Hence, the instant petition, anchored on the following

grounds:

A. THE RESPONDENT COMELEC GRAVELY

ABUSED ITS DISCRETION AND ACTED IN
EXCESS AND/OR WITHOUT JURISDICTION IN
REFUSING TO RULE ON THE VALIDITY OR
INVALIDITY OF THE CANDIDACY OR
PURPORTED CERTIFICATE OF CANDIDACY OF
PRIVATE RESPONDENT FARIÑAS.
B. THE RESPONDENT COMELEC GRAVELY
ABUSED ITS DISCRETION AND ACTED IN
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EXCESS AND/OR WITHOUT JURISDICTION IN

TOSSING THE DUTY TO RULE ON THE
VALIDITY OR INVALIDITY OF THE
CANDIDACY OR PURPORTED CERTIFICATE OF
CANDIDACY OF PRIVATE RESPONDENT
FARIÑAS TO THE HOUSE OF
REPRESENTATIVES ELECTORAL TRIBUNAL
(HRET) CONSIDERING THAT THE LATTER
(HRET) OBVIOUSLY LACKS JURISDICTION TO
RULE ON THE ISSUE THEREBY UNDULY
CREATING A VACUUM AND RENDERING
PETITIONER WITHOUT A REMEDY.
C. THE RESPONDENT COMELEC GRAVELY
ABUSED ITS DISCRETION AND ACTED IN
EXCESS AND/OR WITHOUT JURISDICTION IN
NOT RENDERING A RULING, BASED ON THE
FACTS AS STATED IN ITS ASSAILED
RESOLUTION DATED JANUARY 6, 1999 (Annex
“B” hereof) DISQUALIFYING PRIVATE
RESPONDENT FARINAS AS A CANDIDATE FOR
CONGRESSMAN OF THE FIRST LEGISLATIVE
DISTRICT OF ILOCOS NORTE DURING THE
MAY 11, 1998 ELECTIONS, PREMISED ON ITS
FINDINGS THAT “THERE IS NONE IN THE
RECORDS TO CONSIDER RESPONDENT
(FARIÑAS) AN OFFICIAL CANDIDATE TO
SPEAK OF WITHOUT THE FILING OF SAID
CERTIFICATE, HENCE, THERE IS NO
CERTIFICATE OF CANDIDACY TO BE
CANCELLED, CONSEQUENTLY, NO
CANDIDATE TO BE DISQUALIFIED.”
D. THE RESPONDENT COMELEC GRAVELY
ABUSED ITS DISCRETION AND ACTED IN
EXCESS AND/OR WITHOUT JURISDICTION IN
NOT CALLING A SPECIAL ELECTION TO FILL-
UP THE VACANT POSITION OF
CONGRESSMAN OF THE FIRST LEGISLATIVE
DISTRICT OF ILOCOS NORTE DUE TO THE
DISQUALIFICATION OF RESPONDENT
FARIÑAS AS A CANDIDATE THERETO AND

_______________

7 Rollo, p. 49.

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Guerrero vs. Commission on Elections

WHO APPEARS TO HAVE OBTAINED THE

HIGHEST NUMBER OF VOTES CAST IN THE
MAY 11, 1998 ELECTIONS.

We find pertinent for our resolution this issue:

Did the COMELEC commit grave abuse of discretion in
holding that the determination of the validity of the
certificate of candidacy of respondent Fariñas is already
within the exclusive jurisdiction of the Electoral Tribunal
of the House of Representatives?
In its assailed resolution, the COMELEC had noted that
respondent Fariñas had taken his oath and assumed office
as a Member of the8 11th Congress and by express mandate
of the Constitution, it had lost jurisdiction over the case.
Petitioner Guerrero argues that the refusal of the
COMELEC to rule on the validity or invalidity of the
certificate of candidacy of Fariñas amounted to grave abuse
of discretion on its part. He claims that COMELEC failed
in its Constitutional 9duty to uphold and enforce all laws
relative to elections. He relies on Gallardo v. Judge
Tabamo, Jr., 218 SCRA 253 (1993), which reiterated the
doctrine laid down in Zaldivar v. Estenzo, 23 SCRA 533
(1968), that the COMELEC has exclusive charge of the
enforcement and administration of all laws relative to the
conduct of an electoral exercise.

_______________

8 Art. VI, Sec. 17 provides: “The Senate and the House of

Representatives shall each have an Electoral Tribunal which shall be the
sole judge of all contests relating to the election, returns and qualifications
of their respective Members. Each Electoral Tribunal shall be composed of
nine Members, three of whom shall be Justices of the Supreme Court to be
designated by the Chief Justice, and the remaining six shall be Members
of the Senate or the House of Representatives, as the case may be, who
shall be chosen on the basis of proportional representation from the
political parties and the parties or organizations registered under the
party-list system represented therein. The senior Justice in the Electoral
Tribunal shall be its Chairman.”
9 “Art. IX-C, Sec. 2. The Commission on Elections shall exercise the
following powers and functions:
(1) Enforce and administer all laws and regulations relative to the
conduct of an election, plebiscite, initiative, referendum, and recall, x x x”

466

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466 SUPREME COURT REPORTS ANNOTATED

Guerrero vs. Commission on Elections

A special civil action for certiorari may be availed of when

the tribunal, board, or officer exercising judicial or quasi-
judicial functions has acted without or in excess of
jurisdiction and there is no appeal or any plain, speedy,
and adequate remedy in the ordinary course 10
of law for the
purpose of annulling the proceeding. It is the proper
remedy to question any final order, ruling and decision of
the COMELEC rendered11 in the exercise of its adjudicatory
or quasi-judicial powers. But for an action for certiorari to
prosper, there must be a showing that the COMELEC
acted with grave abuse of discretion. This means such
capricious and whimsical exercise of judgment as is
equivalent to lack of jurisdiction or excess thereof, as where
the power is exercised in an arbitrary and despotic manner
by reason of passion or personal hostility, and it must be so
patent as to amount to an evasion of positive duty 12
or a
virtual refusal to perform the duty enjoined by law.
In the present case, we find no grave abuse of discretion
on the part of the COMELEC when it held that its
jurisdiction over Case No. SPA 98-277 had ceased with the
assumption of office of respondent Fariñas as
Representative for the first district of Ilocos Norte. While
the COMELEC is vested with the power to declare valid or
invalid a certificate of candidacy, its refusal to exercise that
power following the proclamation and assumption of the
position by Fariñas is a recognition of the jurisdictional
boundaries separating the COMELEC and the Electoral
Tribunal of the House of Representatives (HRET). Under
Article VI, Section 17 of the Constitution, the HRET has
sole and exclusive jurisdiction over all 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
juris-

_______________

10 Suntay v. Cojuangco-Suntay, 300 SCRA 760, 766 (1998) citing

Sempio v. Court of Appeals, 263 SCRA 617 (1996).
11 Loong v. Commission on Elections, 305 SCRA 832, 852 (1999) citing
Filipinas Engineering and Machine Shop v. Ferrer, 135 SCRA 25 (1985);
Reyes v. Regional Trial Court of Oriental Mindoro, Br. XXXIX, 244 SCRA
41, 45 (1995).

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12 Cuison v. Court of Appeals, 289 SCRA 159, 171 (1998) citing

Esguerra v. Court of Appeals, 267 SCRA 380 (1997).

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VOL. 336, JULY 26, 2000 467

Guerrero vs. Commission on Elections

diction over election contests relating to his election,

returns, and qualifications
13
ends, and the HRET’s own
jurisdiction begins. Thus, the COMELEC’s decision to
discontinue exercising jurisdiction over the case is
justifiable, in deference to the HRET’s own jurisdiction and
functions.
However, petitioner contends that the jurisdiction of the
HRET as defined under Article VI, Section 17 of the
Constitution is limited only to the qualifications prescribed
14
under Article VI, Section 6 of the Constitution.
Consequently, he claims that any issue which does not
involve these constitutional qualifications is beyond the
realm of the HRET. The filing of a certificate of candidacy
being a statutory qualification under the Omnibus Election
Code is outside the pale of the HRET, according to him.
This contention lacks cogency and is far from
persuasive. Article VI, Section 17 of the Constitution
cannot be circumscribed lexically. The word “qualifications”
cannot be read as qualified by the term “constitutional.”
Ubi lex non distinguit noc nos distinguire debemos. Basic is
the rule in statutory construction that where the law15
does
not distinguish, the courts should not distinguish. There
should be no distinction in the application of a law where
none is indicated. For firstly, the drafters of the
fundamental law, in making no qualification in the use of a
general word or expression, must have intended no
distinction at all. Secondly, the courts could only
distinguish where there are facts or circumstances showing

_______________

13 Aquino v. Commission on Elections, 248 SCRA 400, 417-418 (1995);

Romualdez-Marcos v. Commission on Elections, 248 SCRA 300, 340-341
(1995).
14 Art. VI, Sec. 6 provides: “No person shall be a Member of the House
of Representatives unless he is a natural-born citizen of the Philippines
and, on the day of the election, is at least twenty-five years of age, able to
read and write, and, except the party-list representatives, a registered
voter in the district in which he shall be elected, and a resident thereof for

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a period of not less than one year immediately preceding the day of the
election.”
15 Olfato v. Commission on Elections, 103 SCRA 741, 778 (1981).

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468 SUPREME COURT REPORTS ANNOTATED

Guerrero vs. Commission on Elections

that the lawgiver intended a distinction or qualification. In

such a case, the16 courts would merely give effect to the
lawgiver’s intent.
Petitioner further argues that the HRET assumes
jurisdiction only if there is a valid proclamation of the
winning candidate. He contends that if a candidate fails to
satisfy the statutory requirements to qualify him as a
candidate, his subsequent proclamation is void ab initio.
Where the proclamation is null and void, there is no
proclamation at all and the mere assumption of office by
the proclaimed candidate does not deprive the COMELEC
at all of its power to declare such nullity, according to
petitioner. But as we already held, in an electoral contest
where the validity of the proclamation of a winning
candidate who has taken his oath of office and assumed his
post as Congressman
17
is raised, that issue is best addressed
to the HRET. The reason for this ruling is self-evident, for
it avoids duplicity of proceedings and a clash of jurisdiction
between constitutional bodies, with due regard to the
people’s mandate.
Whether respondent Fariñas validly substituted
Chevylle V. Fariñas and whether respondent became a
legitimate candidate, in our view, must likewise be
addressed to the sound judgment of the Electoral Tribunal.
Only thus can we demonstrate fealty to the Constitutional
provision that the Electoral Tribunal of each House of
Congress shall be the “sole judge of all contests relating to
the election,
18
returns, and qualifications of their respective
members.”
WHEREFORE, the petition is hereby DISMISSED for
lack of merit. Costs against petitioner.
SO ORDERED.

          Davide, Jr. (C.J.), Bellosillo, Melo, Puno, Vitug,

Kapunan, Mendoza, Panganiban, Purisima, Pardo, Buena,
Gonzaga-Reyes, Ynares-Santiago and De Leon, Jr., JJ.,
concur.

Petition dismissed.
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_______________

16 Social Security System v. City of Bacolod, 115 SCRA 412, 415 (1982).
17 Lazatin v. Commission on Elections, 157 SCRA 337, 338 (1988).
18 CONST., Art. VI, Section 17.

469

VOL. 336, JULY 27, 2000 469

Heirs of Crisostomo Sucaldito vs. Cruz

Notes.—The HRET’s jurisdiction as the sole judge of all

contests relating to the elections, returns and qualifications
of members of Congress begins only after a candidate has
become a member of the House of Representatives.
(Romualdez-Marcos vs. Commission on Elections, 248
SCRA 300 [1995])
The fact that the HRET is the sole judge of all contests
relating to the elections, returns and qualifications of its
members does not bar the Supreme Court from
entertaining petitions which charge the HRET with grave
abuse of discretion. (Garcia vs. House of Representatives
Electoral Tribunal [HRET], 312 SCRA 353 [1999])

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