G.R. No.

118597 July 14, 1995

JOKER P. ARROYO, petitioner,

vs.
HOUSE OF REPRESENTATIVES ELECTORAL TRIBUNAL (HRET) and AUGUSTO L. SYJUCO,
JR., respondents.

HRET’s Jurisdiction – Excess and Lack Thereof

FACTS: After the May 11, 1992 elections, Arroyo was declared as the duly elected Congressman of the lone
district of Makati. Arroyo won by 13,559 votes over his opponent. His opponent Syjuco protested the
declaration before the HRET. Syjuco alleged that Arroyo won due to massive fraud hence he moved for
revision and recounting. HRET gave way but during the process some HRET employees and personnel
conducted some irregularities to ensure Syjuco’s win. After some paper battles between the two, Syjuco,
realizing that mere revision and recounting would not suffice to overthrow the more than 12,000 votes lead of
Arroyo over him, revised his complaint by including and introducing in his memorandum cum addendum that
his complaint is actually based on a broader and more equitable non-traditional determination of the existence
of the precinct-level document-based anomalies and that the revision he initially sought is just incidental to
such determination. The 3 justices members of the HRET ruled that such amendment is already beyond the
tribunal’s jurisdiction and the 6 representative members ruled otherwise. Consequently, by a vote of 6-3, the
HRET did not dismiss the protest filed by Syjuco and the HRET later declared Syjuco as the winner.

ISSUE: Whether or not HRET acted with grave abuse of discretion amounting to lack or excess of jurisdiction.

HELD: However guised or justified by Syjuco, this innovative theory he introduced for the first time in his
memorandum cum addendum indeed broadened the scope of the election protest beyond what he originally
sought-the mere revision of ballots. From his initial prayer for revision which lays primary, if not exclusive
emphasis on the physical recount and appreciation of ballots alone, private respondent’s belated attempt to
inject this theory at the memorandum stage calls for presentation of evidence (consisting of thousands of
documents) aside from, or other than, the ballots themselves. By having done so, Syjuco in fact intended to
completely abandon the process and results of the revision and thereafter sought to rely on his brainchild
process he fondly coined as “precinct-level document-based evidence.” This is clearly substantial amendment
of the election protest expressly proscribed by Rule 28 of the HRET internal rules.