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G.R. No. L-25716 – 17 SCRA 756 – Political Law – Constitutional Law – The Judiciary – Judicial Power Defined – The Presidential Electoral Tribunal is constitutional
Fernando Lopez and Gerardo Roxas were the candidates for Vice President in the 1965 elections. Lopez won the election. Roxas appealed his loss before the Presidential Electoral Tribunal (PET). The PET was created by RA 1793. It is provided in the law that:
“There shall be an independent Presidential Electoral Tribunal . . . which shall be the sole judge of all contests relating to the election, returns, and qualifications of the president-elect and the vice-president elect of the Philippines.”
In effect, a losing candidate would have the right to appeal his loss. Lopez questioned the law and he sought to enjoin Roxas and the PET from proceeding with the case. Lopez averred that the PET is unconstitutional for it was not provided for in the constitution. Also, since the PET is composed of the Chief Justice and the other ten members of the SC any decision of the PET cannot be validly appealed before the SC or that conflict may arise once a PET decision is appealed before the SC.
ISSUE: Whether or not the PET is a valid body.
HELD: Yes. In coming up with the PET, the Congress merely conferred a new function to the Supreme Court. Such is within its power, the Constitution allowed Congress to determine which body should decide controversies relating to the election of the President or the Vice President. RA 1793 did not create another court within the SC for pursuant to the Constitution, “the Judicial power shall be vested in one SC and in such inferior courts as may be established by law”
The Supreme Court went on to emphasize that the fundamental law vests in the judicial branch of the government, not merely some specified or limited judicial power, but “the” judicial power under our political system, and, accordingly, the entirety or “all” of said power, except, only, so much as the Constitution confers upon some other agency, such as the power to “judge all contests relating to the election, returns and qualifications” of members of the Senate and those of the House of Representatives, which is vested by the fundamental law solely in the Senate Electoral Tribunal and the House Electoral Tribunal, respectively.
Judicial power is the authority to settle justiciable controversies or disputes involving rights that are enforceable and demandable before the courts of justice or the redress of wrongs for violations of such rights. The proper exercise of said authority requires legislative action: (1) defining such enforceable and demandable rights and/or prescribing remedies for violations thereof; and (2) determining the court with jurisdiction to hear and decide said controversies or disputes, in the first instance and/or on appeal. For this reason, the Constitution ordains that “Congress shall have the power to define, prescribe, and apportion the jurisdiction of the various courts”, subject to the limitations set forth in the fundamental law.
The SC ruled that the PET is not in conflict with the constitution. RA 1793 merely added the court’s jurisdiction and such can be validly legislated by Congress. It merely conferred upon the SC additional functions i.e., the functions of the PET. This is valid because the determining of election contests is essentially judicial.