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Case Digest: Macalintal v.

PET
G.R. No. 191618: November 23, 2010

to decide presidential and vice-presidential election protests while


concurrentlyacting as an independent Electoral Tribunal.

ATTY. ROMULO B. MACALINTAL, Petitioner, v. PRESIDENTIAL


ELECTORAL TRIBUNAL, Respondent.

Verba legisdictates that wherever possible, the words used in the


Constitution must be given their ordinary meaning except where technical
terms are employed, in which case the significance thus attached to them
prevails. However, where there is ambiguity or doubt, the words of the
Constitution should be interpreted in accordance with the intent of its
framers orratio legis et anima. A doubtful provision must be examined in
light of the history of the times, and the condition and circumstances
surrounding the framing of the Constitution. Last,ut magis valeat quam
pereat the Constitution is to be interpreted as a whole.

Nachura, J.:
FACTS:
Atty. Romulo Macalintal questions the constitutionality of the Presidential
Electoral Tribunal(PET) as an illegal and unauthorized progeny of Section
4,Article VII of the Constitution.
ISSUES:
Whether the creation of the Presidential Electoral Tribunal is
unconstitutional for being a violation of paragraph 7, Section 4 of Article VII
of the 1987 Constitution
Whether the designation of members of the supreme court as members of
the presidential electoral tribunal is unconstitutional for being a violation of
Section 12, Article VIII of the 1987 Constitution

By the same token, the PET is not a separate and distinct entity from the
Supreme Court, albeit it has functions peculiar only to the Tribunal. It is
obvious that the PET was constituted in implementation of Section 4,
Article VII of the Constitution, and it faithfully complies not unlawfully
defies the constitutional directive. The adoption of a separate seal, as well
as the change in the nomenclature of the Chief Justice and the Associate
Justices into Chairman and Members of the Tribunal, respectively, was
designed simply to highlight the singularity and exclusivity of the Tribunals
functions as a special electoral court. the PET, as intended by the framers
of the Constitution, is to be an institutionindependent,but not separate,
from the judicial department,i.e., the Supreme Court.

HELD:
Second Issue:
Constitutional Law
First Issue:
Petitioner, a prominent election lawyer who has filed several cases before
this Court involving constitutional and election law issues, including,
among others, the constitutionality of certain provisions of Republic Act
(R.A.) No. 9189 (The Overseas Absentee Voting Act of 2003),cannot claim
ignorance of: (1) the invocation of our jurisdiction under Section 4, Article
VII of the Constitution; and (2) the unanimous holding thereon.
Unquestionably, theoverarching frameworkaffirmed inTecson v.
Commission on Electionsis that the Supreme Court has original jurisdiction

It is also beyond cavil that when the Supreme Court, as PET, resolves a
presidential or vice-presidential election contest, it performs what is
essentially a judicial power. In the landmark case ofAngara v. Electoral
Commission,Justice Jose P. Laurel enucleated that "it would be
inconceivable if the Constitution had not provided for a mechanism by
which to direct the course of government along constitutional channels." In
fact,Angarapointed out that "[t]he Constitution is a definition of the powers
of government." And yet, at that time, the 1935 Constitution did not
contain the expanded definition of judicial power found in Article VIII,
Section 1, paragraph 2 of the present Constitution.

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DENIED
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