BONDOC VS PINEDA

G.R. No. 97710 September 26, 1991

GRIO-AQUIÑO, J.:p

FACTS:

In the 1987 elections, respondent Pineda of Laban ng Demokratikong

Pilipino (LDP) was proclaimed winner over rival petitioner Bondoc of the
Nacionalista Party (NP) for the position of Representative for the 4th District of
Pampanga. Bondoc filed a protest with HRET and was proclaimed winner over
Pineda after revision, re-examination and re-appreciation of the ballots. Among the
members of the HRET who voted for proclamation of Bondoc was Rep. Camasura
of the LDP.

Thereafter, Congressman Camasura received a letter informing him that he

was expelled from the LDP for allegedly helping organize the Partido Pilipino of
Eduardo Cojuangco and inviting LDP members to join. The House voted for Cong.
Cmasura’s removal from the HRET and that his vote be withdrawn, and, upon the
request of LDP, his election to the HRET was rescinded. The promulgation of
Bondoc as winner was then cancelled due to the consequent lack of the required
concurrence of five members of the Tribunal. Hence this petition.

ISSUE:

May the House of Representatives, at the request of a political party, change

that party’s representation in the HRET?

HELD:

No. The Electoral Tribunal was created to function as a nonpartisan court.

To be able to exercise its exclusive jurisdiction, the tribunal must be independent.
Its jurisdiction is not to be shared by it with the Legislature nor with the Courts.
They must discharge their functions with complete independence—even
independence from the political party to which they belong. In expelling Rep.
Camasura for having cast a “conscience vote”, the House of Reps committed a
grave abuse of discretion violative of the Constitution and thus the expulsion is
null and void. To sanction such interference by the House of Reps in the work of
the HRET, would reduce it to a mere tool for the aggrandizement of the party in
power.

WHEREFORE, the petition for certiorari, prohibition and mandamus is

granted. The decision of the House of Representatives withdrawing the nomination
and rescinding the election of Congressman Juanita G. Camasura, Jr. as a member
of the House Electoral Tribunal is hereby declared null and void ab initio for being
violative of the Constitution, and Congressman Juanita G. Camasura, Jr. is ordered
reinstated to his position as a member of the House of Representatives Electoral
Tribunal. The HRET Resolution No. 91-0018 dated March 14, 1991, cancelling the
promulgation of the decision in HRET Case No. 25 ("Dr. Emigdio Bondoc vs.
Marciano A. Pineda") is also set aside.