Case Digest: Bondoc vs Pineda

ISSUE:  Whether or not the House of Representatives is empowered to interfere with election protests in the HRET by reorganizing the representation of the majority party in the HRET? 

FACTS:  On May 11, 1987, the petitioner (NP) and Pineda (LDP) were rival candidates for Congressman of the Fourth District of Pampanga. Pineda was proclaimed the winner having garnered a total of 31,700 votes compared to Bondoc’s 28,400 votes. The petitioner filed a protest with the HRET, composed of 9 members, 3 Justices of the Supreme Court, 6 members of the House chosen on the basis of proportional representation from political parties. A decision was reached declaring Bondoc as the winner by 23 votes, another recount was insisted by the LDP members of the tribunal which increased Bondoc to 107 votes more than Pineda’s. Congressman Camasura (LDP) along with the Justices, voted to proclaim Bondoc as the winner. 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 Cmasura’s removal from the HRET and that his vote be withdrawn. 

DECISION:  Petition for certiorari, prohibition and mandamus is granted 

RATIO DECIDENDI:  No, pursuant to Sec. 17 of Art. VI, the HRET is sole judge of all contests in relation to the election, returns and qualification of their members. It is created as non-partisan court to provide an independent and impartial tribunal for determination of contests. The House cannot just shuffle and manipulate the political component for their benefit and interests. The alleged “party disloyalty” of Cong. Camasura, as a reason for his removal from the party, when he voted in favor of Bondoc, undermines the independence of the HRET. Such members of the HRET have security of tenure. They can only be replaced in cases of term expiration, death, permanent disability, resignation from the party. Disloyalty is not a valid cause of termination.