a. Masangcay v. COMELEC, G.R. No. L-13827, 28 September 1962.

Facts:
On October 14, 1957, Benjamin Masangcay (petitioner), then provincial treasurer
of Aklan designated to take charge of the receipt and custody of the official ballots,
election forms, supplies, as well as of their distribution, among the different
municipalities of Aklan, (with several others), was charged before the COMELEC with
contempt (in violation of the COMELEC’s instructions embodied in its Resolution) for
opening three (3) boxes containing official and sample ballots for the municipalities of
the said province without the presence of the division superintendent of schools of
Aklan, the provincial auditor, and the authorized representatives of the Nacionalist
Party, the Liberal Party, and the Citizens’ Party. Such an act was punishable under
Section 5 of the Revised Election Code.

On December 16, 1957, COMELEC rendered its decision finding Masangcay and
his co-respondent Molo guilty as charged and sentencing each of them to suffer three
(3) months imprisonment and pay a fine of PhP 500, with subsidiary imprisonment of
two (2) months in case of insolvency, to be served in the provincial jail of Aklan.

Masangcay brought this present petition challenging the constitutionality of

Section 5 of Revised Election Code which grants COMELEC (as well as its members) the
power to punish acts of contempt. In other words, even if Masangcay can be held guilty
of the act of contempt charged, the decision is null and void for lack of valid power on
the part of COMELEC to impose such disciplinary penalty under the principle of
separation of powers.
 
Issue: Whether or not COMELEC has the power to punish Masangcay for contempt?

Held: NO. COMELEC has exceeded its jurisdiction in punishing him for contempt, and
so its decision is null and void. Under the law and Constitution, COMELEC only has
the duty to enforce and administer all laws to the conduct of elections, but also the
power to try, hear and decide any controversy that may be submitted to it in connection
with the elections. COMELEC may however exercise quasi-judicial functions insofar as
controversies that by express provision law come under its jurisdiction.

Also, when COMELEC exercises an administrative function or ministerial

function, it cannot exercise the power to punish contempt because such power is
inherently judicial in nature. The resolutions which COMELEC tried to enforce (and
for whose violation contempt was filed against Masangcay) merely call for the exercise
of an administrative or ministerial function for they merely concern the procedure to
be followed in doing his tasks.