COMMISSION ON ELECTIONS
GUEVARA VS. COMMISSION ON ELECTIONS (104 SCRA 268)
FACTS:
The facts which gave rise to the present contemptuous incident are: The Commission on Elections, on May 4, 1957, after proper negotiations, awarded to the National Shipyards & Steel Corporation (NASSCO), the Acme Steel Mfg. Co., Inc. (ACME), and the Asiatic Steel Mfg. Co., Inc. (ASIATIC), the contracts to manufacture and supply the Commission 12,000, 11,000 and 11,000 ballot boxes at P17.64, P14.00 and P17.00 each, respectively. On May 8, 1957, both the NASSCO and the ASIATIC signed with the Commission on Elections the corresponding contracts thereon. On May 13, 1957, the Commission cancelled the award to the ACME for failure of the latter to sign the contract within the designated time and awarded to the NASSCO and the ASIATIC, one-half each, the 11,000 ballot boxes originally alloted to the ACME. The corresponding contracts thereon were signed on May 16, 1957.
Then followed a series of petitions filed by the ACME for the reconsideration of the resolution of the Commission of May 13, 1957. The first of these petitions was filed on May 14, 1957 which, after hearing, was denied by the Commission in its resolution of May 16, 1957. The second petition was filed on May 16, 1957 and was denied on May 17, 1957. The third petition was filed on May 20, 1957, and because of the seriousness of the grounds alleged therein for the annulment of its previous resolutions, the Commission resolved to conduct a formal investigation on the matter ordering the NASSCO and the ASIATIC to file their respective answers. Thereafter, after these corporations had filed their answers, the Commission held a formal hearing thereon on May 24, 1957. On May 28, 1957, the ACME filed a memorandum on the points adduced during the hearing, and on June 4, 1957, the Commission issued its resolution denying the third motion for reconsideration. The article signed by petitioner was published in the June 2, 1957 issue of the Sunday Times, a newspaper of nationwide circulation.
ISSUE:
The question to be determined is whether the Commission on Elections has the power and jurisdiction to conduct contempt proceedings against petitioner with a view to imposing upon him the necessary disciplinary penalty in connection with the publication of an article in the Sunday Times issue of June 2, 1957 which, according to the charge, tended to interfere with and influence said Commission in the adjudication of a controversy then pending determination and to degrade and undermine the function of the Commission and its members in the administration of all laws relative to the conduct of elections.
HELD:
It would therefore appear that the Commission on Elections not only has the duty to enforce and administer all laws relative to the conduct of elections but the power to try, hear and decide any controversy that may be submitted to it in connection with the elections. And as an incident of this power, it may also punish for contempt in those cases provided for in Rule 64 of the Rules of Court under the same procedure and with the same penalties provided therein. In this sense, the Commission, although it cannot be classified as a court of justice within the meaning of the Constitution (Section 13, Article VIII), for it is merely an independent administrative body (The Nacionalista Party vs. Vera, 85 Phil., 126; 47 Off. Gaz. 2375), may however exercise quasi-judicial functions in so far as controversies that by express provision of the law come under its jurisdiction. As to what questions may come within this category, neither the Constitution nor the Revised Election Code specifies. The former merely provides that it shall come under its jurisdiction, saving those involving the right to vote, all administrative questions affecting elections, including the determination of the number and location of polling places, and the appointment of election inspectors and other election officials, while the latter is silent as to what questions may be brought before it for determination. But it is clear that, to come under its jurisdiction, the questions should be controversial in nature and must refer to the enforcement and administration of all laws relative to the conduct of election. The difficulty lies in drawing the demarcation line between a duty which inherently is administrative in character and a function which is justiciable and which would therefore call for judicial action by the Commission. But this much depends upon the factors that may intervene when a controversy should arise.
RULING OF COURT:
Wherefore, petition is granted. Respondent Commission is hereby enjoined from proceeding with the contempt case set forth in its resolution of June 20, 1957, without pronouncement as to costs.
The preliminary injunction issued by this Court is made permanent.
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