Case Title and Citation: Guevarra vs COMELEC, 1958

FACTS:
The case revolved around the Commission on Elections' handling of contracts for the
manufacture and supply of 34,000 ballot boxes. Initially, on May 4, 1957, the Commission
awarded contracts to National Shipyards & Steel Corporation (NASSCO), Acme Steel Mfg.
Co., Inc. (ACME), and Asiatic Steel Mfg. Co., Inc. (ASIATIC) for 12,000, 11,000, and
11,000 ballot boxes, respectively. NASSCO and ASIATIC signed their contracts on May 8,
1957. However, on May 13, 1957, the Commission canceled ACME's award due to their
failure to sign within the allotted time and split ACME's 11,000 boxes between NASSCO and
ASIATIC. Their contracts were signed on May 16, 1957.
This decision led ACME to file a series of petitions for reconsideration. The first
petition on May 14, 1957, was denied on May 16, 1957. The second petition on May 16,
1957, was denied the next day. The third and final petition on May 20, 1957, raised serious
grounds for annulment, prompting the Commission to conduct a formal investigation. This
investigation involved hearings, submissions of answers by NASSCO and ASIATIC, and a
formal hearing on May 24, 1957. ACME submitted a memorandum on May 28, 1957.
The Commission then issued a resolution on June 4, 1957, denying ACME's third
motion for reconsideration. Amidst this ongoing dispute, the Petitioner published an article
titled "Ballot Boxes Contract Hit" in the Sunday Times on June 2, 1957. This article allegedly
interfered with and influenced the Commission and its members in the resolution of the
controversy. The Commission accused the article of degrading its function and bringing it
into disrepute in the execution of its duties related to the conduct of elections.

ISSUE:
Whether the Commission on Elections has the authority and jurisdiction to conduct
contempt proceedings against the Petitioner for publishing an article titled "Ballot Boxes
Contract Hit" in the Sunday Times on June 2, 1957.

RULING:
The Supreme Court ruled in favor of the Petitioner in this case, finding that the
Commission on Elections did not have the power or authority to subject the Petitioner to
contempt proceedings for publishing the article titled "Ballot Boxes Contract Hit" in the
Sunday Times on June 2, 1957. The Court held that the Commission, as an independent
administrative body tasked with enforcing and administering election laws, did not possess
the inherent judicial power to punish for contempt in cases like the one involving the
publication of the article by the Petitioner.
The Court emphasized that the Commission's role in this matter was primarily
administrative, relating to the procurement of necessary ballot boxes for elections. The
negotiations and controversies surrounding the awarding of contracts for ballot boxes
constituted ministerial duties of the Commission, not judicial functions. Therefore, the
Commission could not exercise the power to punish for contempt as postulated in the law,
which is inherently judicial in nature. As a result, the Supreme Court granted the petition,
enjoined the Commission from proceeding with the contempt case against the Petitioner, and
made the preliminary injunction permanent.