Primary Holding

The Supreme Court held that the special election to fill the Senate vacancy was validly held, and COMELEC’s failure to give formal notice did not invalidate the election. The petition was dismissed for lack of merit.

Background

Following the appointment of Senator Teofisto Guingona as Vice-President in 2001, a Senate vacancy arose. The Senate passed a resolution calling for a special election to fill the vacancy, to be held simultaneously with the May 14, 2001, regular elections. The 13th placer in the senatorial race would serve the unexpired term. Petitioners challenged the validity of the special election, arguing that COMELEC failed to comply with legal requirements.

Facts

• 1. Senator Guingona was appointed Vice-President, creating a Senate vacancy.
• 2. Senate Resolution No. 84 called for a special election to fill the vacancy, to be held simultaneously with the May 14, 2001, regular elections.
• 3. COMELEC proclaimed 13 senators, with the 13th placer (Honasan) to serve the unexpired term.
• 4. Petitioners challenged the validity of the special election, arguing that COMELEC failed to notify candidates, specify the election type, and separately canvass votes.

Arguments of the Petitioners

• 1. COMELEC failed to notify candidates about the special election.
• 2. COMELEC failed to specify in the Voters Information Sheet the candidates seeking election under the special or regular elections.
• 3. COMELEC failed to separately canvass votes for the special and regular elections.
• 4. The special election was invalid due to lack of proper notice and documentation.

Arguments of the Respondents

• 1. The special election was validly held.
• 2. The petition is moot as the senators have already been proclaimed and taken their oaths.
• 3. Petitioners lack standing to sue.
• 4. The petition is essentially a quo warranto petition, which should be filed with the Senate Electoral Tribunal.

Issues

• 1. Is the petition a quo warranto petition?
• 2. Is the petition moot?
• 3. Do petitioners have standing to litigate?
• 4. On the merits: Was the special election validly held?

Ruling

• 1. The petition is not a quo warranto petition but a challenge to the validity of the special election.
• 2. The petition is not moot as the issue is capable of repetition yet evading review.
• 3. Petitioners have standing as voters raising issues of public importance.
• 4. The special election was validly held. COMELEC’s failure to give formal notice did not invalidate the election, as the law charged voters with knowledge of the special election.
• 5. Separate documentation and canvassing were not required by law.
• 6. The method adopted by COMELEC was a legitimate exercise of its discretion.

Doctrines

• 1. Capable of Repetition Yet Evading Review: Courts may decide moot cases if the issue is likely to recur but evade review.
• 2. Standing to Sue: Voters have standing to challenge election irregularities affecting their right to suffrage.
• 3. COMELEC’s Discretion: COMELEC has wide latitude in conducting elections, provided it does not act illegally or with grave abuse of discretion.

Precedents Cited

• 1. “The consistent rule has been to respect the electorate’s will and let the results of the election stand, despite irregularities that may have attended the conduct of the elections.”

Statutory and Constitutional Provisions

• 1. Section 9, Article VI of the Constitution: Provides for special elections to fill vacancies in Congress.
• 2. Republic Act No. 6645: Governs the conduct of special elections to fill congressional vacancies.
• 3. Section 73 of Batas Pambansa Blg. 881 (Omnibus Election Code): Requires candidates to file certificates of candidacy.
• 4. Section 4, Paragraph 4 of Republic Act No. 6646: Requires the printing of candidates’ names in election returns and tally sheets.