Vinzons-Chato v.

Comelec
Ratio:
it avoids duplicity of proceedings and a clashof jurisdiction between constitutional bodies with
dueregard to the peoples mandate.
-Special civil action for
certiorari
shall prosper if thefollowing requisites concur:
o
Tribunal, board or officer exercising judicial orquasi-judicial functions has acted without or
inexcess of jurisdiction or with grave abuse of jurisdiction amounting to lack of jurisdiction
o
There is no appeal or any plain, speedy andadequate remedy in the ordinary course of law
toannul or modify the proceeding.-In this case, COMELEC did not commit rave abuse
of discretion when it issued a resolution holding that ithad lost jurisdiction upon Unicos
proclamation. Itdemonstrated fealty to the constitutional fiatregarding HRET.
Facts:
Unico has already been proclaimed and takenhis oath of office as a Member of the HOR,
hence,Comelec ruled that it had already lost jurisdiction overpetitioner Chatos election protest
against Unicoregarding canvassing of returns and alleged invalidityof Unicos proclamation. He
then filed a special civilaction for
certiorari
in the SC.
Issue: WON the court should take cognizance of Chatos election protest. If not, to who is this
issuebest addressed to? WON his civil action for
certiorari
will prosper.
Held: The court should not take cognizance of Chatoselection protest for it would amount to
usurpation of the constitutionally mandated functions of the HRET.Civil action for
certiorari
will not prosper.Ratio: - In an electoral contest where the validity of theproclamation of a
winning candidate who has taken hisoath of office and assumed his post as Congressman
israised, that issue is best addressed to the HRET.