Political Law

Joker Arroyo vs HRET & Augusto Syjuco

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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.


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