### Facts:
The case originated from an election contest filed by Firdausi Smail Abbas and other petitioners against 22 candidates of the LABAN coalition, who were proclaimed senators-elect in the May 11, 1987, congressional elections by the Commission on Elections. This was docketed as SET Case No. 002-87 before the Senate Electoral Tribunal (SET), which at that time comprised three Supreme Court Justices and six Senators. The petitioners, excluding Senator Joseph E. Estrada but including Senator Juan Ponce Enrile, filed a Motion for Disqualification or Inhibition against the Senators-Members of the SET, claiming they were interested parties in the case. Senator Enrile later voluntarily inhibited himself from the proceedings due to his personal involvement. After hearing oral arguments and receiving memoranda on the issue, the SET denied the motion and its subsequent motion for reconsideration, prompting the petitioners to elevate the matter to the Supreme Court through a Special Civil Action for certiorari.
### Issues:
1. Whether the petitioners’ request for the mass disqualification or inhibition of Senator-Members of the SET from hearing SET Case No. 002-87 is constitutionally permissible.
2. Whether the SET acted within its discretion in denying the petitioners’ motion for disqualification or inhibition.
### Court’s Decision:
The Supreme Court dismissed the petition for lack of merit. It held that the Constitution explicitly mandates a mixed composition of the SET, including both Supreme Court Justices and Senators, to adjudicate electoral contests. The Court reasoned that the proposed mass disqualification sought by the petitioners was neither feasible nor constitutional, as it would leave the Tribunal incapable of performing its duties as envisaged by the Constitution. The Court emphasized the importance of the Tribunal’s duty and authority to decide all contests relating to the election, returns, and qualifications of Senators, a duty that cannot be performed by any other body. The decision to inhibit from the SET proceedings remains a matter of personal conscience for its members, provided that the constitutional mandate for the SET’s composition is not compromised.
### Doctrine:
The case reaffirmed the constitutional provision on the composition and powers of the Senate Electoral Tribunal (SET), emphasizing the imperative that it operates with a combination of judicial and legislative components as specified in the Constitution. The doctrine underscores the principle that the mixed “judicial” and “legislative” makeup of the SET is fundamental to its function and authority in deciding electoral contests for the Senate, reflecting a key balance between legislative peer representation and judicial oversight.
### Class Notes:
– **Composition of the SET:** Constitutionally mandated to include three Justices of the Supreme Court and six Senators, demonstrating a balance of judicial and legislative oversight.
– **Electoral Tribunal’s Authority:** Sole judge of all contests relating to the election, returns, and qualifications of its respective Members.
– **Doctrine of Necessity:** Highlighted in the context that the SET must function despite potential conflicts of interest, due to its unique authority and duties.
– **Disqualification and Inhibition:** Members may voluntarily inhibit themselves based on personal biases or interests, but mass disqualification that impedes the body’s functionality is unconstitutional.
### Historical Background:
The case reflects the challenges inherent in adjudicating electoral disputes within the unique political and constitutional framework of the Philippines. It underscores the delicate balance between ensuring fair and impartial adjudication of electoral contests and adhering to the constitutional prerogatives established for such tribunals. The litigation emerged from the contentious 1987 elections, marking a crucial period of political transition and democratization in the Philippines post-Marcos era. The constitutional provisions for the SET were designed to embody a blend of judicial prudence and legislative representation, a model reflecting the broader democratic ethos and checks and balances envisioned in the 1987 Constitution.
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