CASE DIGESTS

FACTS: Fernando Poe Jr. (FPJ) filed an election protest at the Presidential Electoral Tribunal (PET) against the proclaimed winner of the 2004 presidential elections. During the pendency of the case, FPJ died. His widow, Susan Roces, claimed before the PET that there was an urgent need for her to substitute her husband in the election protest that he had filed as it is of paramount interest to the Filipino people. ISSUE: May the widow substitute/intervene for the protestant who died during the pendency of the latter’s presidential protest case? RULING: No. The fundamental rule applicable in a presidential election protest is Rule 14 of the PET Rules. It provides that only the registered candidate for President or Vice President of the Philippines who has received the second or third highest number of votes may timely contest the election of the proclaimed winner. Furthermore, a public office is personal to the public officer and is not a property capable of being transmitted to his hei

FACTS: Petitioners questioned the jurisdiction of the COMELEC in taking cognizance of and deciding the citizenship issue affecting Fernando Poe Jr. They asserted that under Section 4(7) , Article VII of the 1987 Constituition, only the Supreme Court had original and exclusive jurisdiction to resolve the basic issue of the case. ISSUE: As the Presidential Electoral Tribunal (PET) , does the Supreme Court have jurisdiction over the qualifications of presidential candidates? RULING: No. An examination of the phraseology in Rule 12, 13, and Rule 14 of the "Rules of the Presidential Electoral Tribunal," promulgated by the Supreme Court on April 1992 categorically speak of the jurisdiction of the tribunal over contests relating to the election, returns and qualifications of the "President" or "Vice-President", of the Philippines, and not of "candidates" for President or Vice-President. A quo warranto proceeding is generally defined as being an action

FACTS: Congress enacted RA 8436 authorizing COMELEC to use an automated election system for the process of voting, counting of votes and canvassing/consolidation the results of national and local elections. COMELEC subsequently approved Resolution 6712 adopting the policy that the precinct election results of each city and municipality shall be immediately transmitted electronically in advance to the COMELEC in Manila. Petitioners in this case questioned, among others, the Constitutionality of the quickcount as being pre-emptive of the authority vested in Congress to canvass the votes for the President and Vice-President under Article VII, Section 4 of the 1987 Constitution. ISSUE: Can the COMELEC conduct “unofficial” tabulation of presidential election results based on a copy of the election returns? RULING: No. The assailed resolution usurps, under the guise of an “unofficial” tabulation of election results based on a copy of the election returns, the sole and exclusive authority of