G.R. No. 97710.
September 26, 1991 (Case Brief / Digest)
Title: Bondoc vs. Pineda and the House of Representatives Electoral Tribunal
Facts:
The controversy revolves around the membership of the House of Representatives Electoral
Tribunal (HRET) and its independence as a judicial body tasked with resolving election
disputes concerning House members. Dr. Emigdio A. Bondoc, a Nacionalista Party
candidate, lost the congressional election for the Fourth District of Pampanga to Marciano
M. Pineda of the Laban ng Demokratikong Pilipino (LDP) and subsequently filed an electoral
protest (HRET Case No. 25). The HRET, composed of three Supreme Court Justices and six
House members, deliberated on the case. In October 1990, a decision favoring Bondoc was
reached but delayed by the re-appreciation of ballots, ultimately increasing Bondoc’s
winning margin. A pivotal moment occurred when Congressman Juanito G. Camasura, Jr.,
an LDP member of the HRET, sided with Bondoc, leading to his expulsion from LDP and
removal from HRET by the House, ostensibly to block the promulgation of the HRET
decision supporting Bondoc. The Supreme Court was petitioned to review the House’s
actions, presenting weighty constitutional questions.
Issues:
1. Whether the House of Representatives can alter its representation in the HRET to
influence the outcome of an electoral contest.
2. Whether the Supreme Court can review and nullify the House’s actions regarding HRET
membership changes.
3. The implications of such House actions on the independence of the HRET and
constitutional rights, including security of tenure for HRET members.
Court’s Decision:
The Supreme Court ruled in favor of Bondoc, declaring the House’s action to remove
Camasura from the HRET as unconstitutional. It held that the House of Representatives
cannot interfere with the HRET’s decision-making to protect the interests of a political
party, as such interference undermines the HRET’s constitutionally guaranteed
independence as the “sole judge” of electoral contests. The Court also emphasized that
membership in the HRET should not be terminated for political reasons, protecting
members’ security of tenure.
Doctrine:
This case reinforces the doctrine that the House of Representatives Electoral Tribunal
(HRET) operates independently of the Legislature, based on the constitutional mandate that
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G.R. No. 97710. September 26, 1991 (Case Brief / Digest)
designates the HRET as the “sole judge” of electoral contests related to House members. It
established that the judiciary has the authority to rule on actions by other branches of
government when these actions impinge on individual rights or contravene constitutional
limits, affirming the duty of the judiciary to ensure the supremacy of the Constitution.
Class Notes:
– HRET Composition: Three Supreme Court Justices and six House members, chosen based
on proportional representation from political parties.
– HRET Independence: Sole jurisdiction over electoral contests; House cannot interfere.
– Security of Tenure for HRET Members: Membership cannot be terminated for political
reasons.
– Judicial Review: The Supreme Court can examine actions by the legislative and executive
branches if these actions violate constitutional rights or exceed granted powers.
Historical Background:
The case underlines the evolution of the Philippine judiciary from a more passive role
concerning political questions to a more assertive stance in protecting constitutional
mandates and individual rights. This shift reflects a broader global trend of judicial bodies
ensuring that legislative and executive actions remain within the bounds of constitutional
authority, balancing the principle of separation of powers with the need to safeguard
democratic institutions and processes.
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