Cassandra Danielle T.

Layson 1-Manresa
Electoral Tribunal
Fernandez vs. HRET
608 SCRA 733 (2009)

Facts:
Danilo Ramon S. Fernandez filed for candidacy as Representative of the First Legislative
District of the Province of Laguna in May 14, 2007 elections. In his Certificate of Candidacy
(COC), he indicated his complete/exact address as No. 13 Maharlika St., Villa Toledo Subdivision,
Barangay Baliboago, Sta. Rosa City, Laguna (alleged Sta. Rosa residence).
Private respondent Jesus L. Vicente filed a Petition to Deny Due Course to and/or Cancel
Certificate of Candidacy and Petition for Disqualification before the Office of the Provincial
Election Supervisor of Laguna. This was forwarded to the Commission on Elections (COMELEC).
Vicente sought the cancellation of petitioners COC and the latter’s disqualification as a candidate
on the ground of an alleged material misinterpretation in his COC regarding his place of residence,
because during past elections, he had declared Pagsanjan, Laguna as his address, and Pagsanjan
was located in the Fourth Legislative District of the Province of Laguna. Vicente likewise claimed
that petitioner maintained another house in Cabuyao, Laguna, which was also outside of the First
District.
The COMELEC (First Division) dismissed said petition for lack of merit. Subsequently,
petitioner was proclaimed as the duly elected Representative of the First District of Laguna on
June 27, 2007.
On July 5, 2007, Vicente filed a petition for quo warranto before the House of
Representative Electoral Tribunal, praying that Fernandez be declared ineligible to hold office as
a Member of the House of Representative representing the First Legislative District of the Province
of Laguna, and that Fernandez’s election and proclamation be annulled and declared null and void.
The HRET granted Vicente’s prayer and disqualified Fernandez.
Fernandez challenged the HRET’s decision arguing that the they should have been guided
and/or cautioned by the COMELEC’s prior decision wherein he was adjudged as qualified to run
for the position of Congressman of the First District of Laguna. Petitioner claims that the HRET
should have respected the findings of the COMELEC and should have discreetly denied the
petition.

Issue:
Whether or not the HRET is bound by the prior determination of the COMELEC as to the
qualification of the Petitioner

Ruling:
The 1987 Philippine Constitution explicitly provides under Article VI, Section 17 thereof
that the HRET and the Senate Electoral Tribunal (SET) shall be the sole judges of all contests
relating to the election, returns, and qualification of their respective members. The authority
conferred upon the Electoral Tribunal is full, clear and complete. The use of the word sole
emphasizes the exclusivity of the jurisdiction of these Tribunals, which is conferred upon the
HRET and the SET after elections and the proclamation of the winning candidates.
Thus, Vicente correctly pointed out that a petition for quo warranto is within the exclusive
jurisdiction of the HRET, even if, as in this case, the COMELEC had already passed upon in
administrative or quasi-judicial proceedings the issue of the qualification of the Member of the
House of Representatives while the latter was still a candidate.