Bondoc vs. Pineda, 201 SCRA 792, G.R. No.

97710, 26 Sept 1991

Facts:
In t h e e le ct io n s h e l d o n M ay 1 1 , 1 9 8 7 , M arci an o P in e d a o f t h e LD P an d E m ig d io
Bo n d o c o f t h e N P w e re candidates for the position of Representative for the Fourth District of
Pampanga. Pineda was proclaimed winner. Bondoc filed a protest in the House of Representatives
Electoral Tribunal (HRET), which is composed of 9 members,3 of whom are Justices of the SC and the
remaining 6 are members of the House of Representatives (5 members be lo n g t o t h e LD P a n d 1
m e m b e r i s f ro m t h e N P ). T h e re af t e r , a d e c isi o n h ad b e e n re a ch e d in wh ich
Bo n d o c w o n o ve r Pineda. Congressman Camasura of the LDP voted with the SC Justices and
Congressman Cerilles of the NP to proclaim Bondoc the winner of the contest. On the eve of the
promulgation of the Bondoc decision, Congressman Camasura received a letter informing him that
h e wa s a lr e ad y e x p e lle d f ro m t h e LD P f o r alle ge d ly h e lp in g t o o r gan iz e t h e
P a r t id o P i lip in o o f E d u ard o Co ju an g co a n d for allegedly inviting LDP members in Davao Del
Sur to join said political party. On the day of the promulgation of the decision, the Chairman of HRET
received a letter informing the Tribunal that on the basis of the letter from the LDP, the House of
Representatives decided to withdraw the nomination and rescind the election of Congressman
Camasura to the HRET.

Issue:
Whether or not the House of Representatives, at the request of the dominant political party therein,
may ch a n g e t h at p ar t y s re p re se n t at io n in t h e H RE T t o t h wa rt t h e p ro mu l ga t io n o f
a d e c isi o n f re e ly re ach e d b y t h e t rib u n al in an e le ct io n co n t e st p e n d in g t h e r e in

Held:
The purpose of the constitutional convention creating the Electoral Commission was to provide an
independent and impartial tribunal for the determination of contests to legislative office, devoid of
partisan consideration. As judges, the members of the tribunal must be non-partisan. They must
discharge their functions with complete d e t ach me n t , imp a rt ia lit y a n d in d e p e n d e n ce e v e n
in d e p e n d e n c e f ro m t h e p o lit i ca l p a rt y t o wh i ch t h e y b e l o n g. He n c e , disloyalty to
party and breach of party discipline are not valid grounds for the expulsion of a member of the
tribunal. In expelling Congressman Camasura from the HRET for having cast a conscience vote in
favor of Bondoc, based strictly on the result of the examination and appreciation of the ballots and
the recount of the votes by the tribunal, the House of Representatives committed a grave abuse of
discretion, an injustice and a violation of the Constitution. Its resolution of expulsion against
Congressman Camasura is, therefore, null and void. Another reason for the nullity of the expulsion
resolution of the House of Representatives is that it violates Congressman Camasuras right to
security of tenure. Members of the HRET, as sole judge of congressional election contests, are
entitled to security of tenure just as members of the Judiciary enjoy security of tenure under the
Constitution. Therefore, membership in the HRET may not be terminated except for a just cause, such
as, the expiration of the members congressional term of office, his death, permanent disability,
resignation from the political party he represents in the tribunal, formal affiliation with another
political party or removal for other valid cause. A member may not be expelled by the House of
Representatives for party disloyalty, short of proof that he has formally affiliated with another.

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