Joker Arroyo vs HRET & Augusto Syjuco

G.R. No. 118597 – 246 SCRA 384 – Political Law – HRET’s Jurisdiction – Excess and Lack Thereof

After the May 11, 1992 elections, Arroyo was declared as the duly elected Congressman of the lone
district of Makati. Arroyo won by 13,559 votes over his opponent. His opponent Syjuco protested the
declaration before the HRET. Syjuco alleged that Arroyo won due to massive fraud hence he moved
for revision and recounting. HRET gave way but during the process some HRET employees and
personnel conducted some irregularities to ensure Syjuco’s win. After some paper battles between
the two, Syjuco, realizing that mere revision and recounting would not suffice to overthrow the more
than 12,000 votes lead of Arroyo over him, revised his complaint by including and introducing in his
memorandum cum addendum that his complaint is actually based on a broader and more equitable
non-traditional determination of the existence of the precinct-level document-based anomalies and that
the revision he initially sought is just incidental to such determination. The 3 justices members of the
HRET ruled that such amendment is already beyond the tribunal’s jurisdiction and the 6 representative
members ruled otherwise. Consequently, by a vote of 6-3, the HRET did not dismiss the protest filed
by Syjuco and the HRET later declared Syjuco as the winner.

ISSUE: Whether or not HRET acted with grave abuse of discretion amounting to lack or excess of
jurisdiction.

HELD: However guised or justified by Syjuco, this innovative theory he introduced for the first time
in his memorandum cum addendum indeed broadened the scope of the election protest beyond what
he originally sought-the mere revision of ballots. From his initial prayer for revision which lays
primary, if not exclusive emphasis on the physical recount and appreciation of ballots alone, private
respondent’s belated attempt to inject this theory at the memorandum stage calls for presentation of
evidence (consisting of thousands of documents) aside from, or other than, the ballots themselves. By
having done so, Syjuco in fact intended to completely abandon the process and results of the revision
and thereafter sought to rely on his brainchild process he fondly coined as “precinct-level document-
based evidence.” This is clearly substantial amendment of the election protest expressly proscribed by
Rule 28 of the HRET internal rules.