Primary Holding

The HRET’s rules, not the Omnibus Election Code, govern the filing period for congressional election protests; Timbol’s protest was timely filed under HRET’s 15-day rule.

Background

The case arose from the 1987 congressional election in Pampanga, where Timbol contested Lazatin’s proclamation due to alleged irregularities. After prolonged COMELEC proceedings, the Supreme Court reinstated Lazatin’s proclamation, prompting Timbol to file a protest with the HRET.

Facts

• 1. The 1987 congressional election in Pampanga’s 1st District saw Carmelo Lazatin proclaimed winner on May 27, 1987. Lorenzo Timbol filed a protest with COMELEC alleging irregularities, leading COMELEC to annul Lazatin’s proclamation on September 15, 1987. The Supreme Court reinstated Lazatin’s victory on January 25, 1988. Timbol then filed an election protest with the HRET on February 8, 1988, which Lazatin contested as untimely under the Omnibus Election Code’s 10-day deadline. The HRET ruled the protest valid under its own 15-day rule, triggering the Supreme Court’s review of jurisdictional authority.

Arguments of the Petitioners

• 1. Timbol’s protest was filed 9 days late under Sec. 250 of the Omnibus Election Code (10-day deadline from proclamation); HRET lacked jurisdiction due to untimeliness.

Arguments of the Respondents

• 1. The HRET’s 15-day rule (Sec. 9 of HRET Rules) applied, as Lazatin’s proclamation was only final on January 28, 1988; the protest was filed 11 days later, within the allowed period.

Issues

• 1. Whether the HRET’s rules or the Omnibus Election Code govern the period for filing congressional election protests.

Ruling

• 1. The Supreme Court upheld the HRET’s authority, ruling that the Tribunal’s 15-day deadline (under Sec. 9 of HRET Rules) superseded the Omnibus Election Code’s 10-day period. Timbol’s protest was deemed timely because the deadline ran from the finality of Lazatin’s proclamation (January 28, 1988), not the original May 1987 proclamation. The Court emphasized that HRET, under Art. VI, Sec. 17 of the Constitution, has exclusive power to regulate procedural matters in congressional election contests, overriding conflicting statutory provisions.

Precedents Cited

• 1. Angara v. Electoral Commission (1936): Affirmed HRET’s authority to set procedural rules.
• 2. Lachica v. Yap (1968): Limited judicial review of HRET decisions.
• 3. Morrero v. Bocar (1938): HRET judgments are beyond judicial interference absent grave abuse.

Statutory and Constitutional Provisions

• 1. 1987 Constitution, Art. VI, Sec. 17: HRET’s jurisdiction over congressional contests.
• 2. Omnibus Election Code, Sec. 250: 10-day protest period for COMELEC contests (deemed inapplicable).
• 3. HRET Rules, Sec. 9: 15-day protest period for 1987 elections.