**Facts:**
1. **Election and Protest:** On July 15, 2002, Walter J. Aragones and Oscar C. Lasola contested for Punong Barangay of Poblacion, Guihulngan, Negros Oriental. Aragones was proclaimed the winner by the election board with 1,614 votes over Lasola’s 1,593. Lasola filed an election protest on July 24, accusing irregularities by the election tellers due to manipulation by an election officer related to Aragones.
2. **MTC Proceedings:** On July 25, 2002, Judge Hector B. Barillo of the MTC ordered the summoning of all parties and safekeeping of ballots. Subsequently, on July 29, he directed a vote revision, setting up a committee to recount ballots with parties depositing P150 per ballot box.
3. **Legal Representations:** On July 31, Aragones’ counsel, Atty. Yap, contested the appearance of Lasola’s lawyer, Atty. Paras, due to his suspension. Nevertheless, Judge Barillo allowed Paras and associates to appear throughout proceedings.
4. **Aragones’ Motions:** Aragones filed motions for Judge Barillo’s inhibition and reconsideration of his July 25 and 29 rulings, citing lack of jurisdiction and bias, which Barillo denied by August 7, 2002.
5. **RTC Involvement:** Aragones filed a certiorari petition on August 8 before RTC seeking inhibition and injunction against Barillo, emphasizing the appearance of an attorney under suspension.
6. **MTC Decision:** On November 27, 2002, MTC rendered its decision favoring Lasola, overturning the initial proclamation and declaring him elected.
7. **Rival RTC Decisions:** An RTC decision on December 3 declared nullity of MTC proceedings, but discrepancies arose with another variant received later, creating confusion over the RTC’s stance, allowing Barillo to execute the MTC decision.
8. **COMELEC Intervention:** Upon Aragones’ petition, COMELEC’s Second Division declared the MTC’s decision as null and void on June 11, 2003, based on insufficiency in form and substance allegations in Lasola’s protest and grave abuse committed by Judge Barillo.
9. **Supreme Court Involvement:** Judge Barillo petitioned the Supreme Court for certiorari in G.R. No. 159117 against the COMELEC Decision, challenging both jurisdiction and allegations of grave abuse sanctioned therein.
**Issues:**
1. **Legal Standing of Judge:** Whether Judge Barillo had legal standing to appeal the COMELEC resolution in G.R. No. 159117.
2. **COMELEC Jurisdiction:** Whether COMELEC’s Second Division could nullify an already promulgated decision by the MTC.
3. **Grave Abuse Determination:** Whether the grave abuse of discretion by Judge Barillo included his permitting a suspended lawyer to appear and pursuing hasty judgments.
4. **Finality of MTC Decision:** Whether the MTC’s decision became final and unchallengeable post five-day appellate window, given Aragones’ failure to appeal.
**Court’s Decision:**
1. **Legal Standing Dismissed:** The Court ruled that Judge Barillo lacked legal standing as his role was merely nominal. Public respondents, without specific directive, shouldn’t actively contest decisions.
2. **COMELEC Authority Upheld:** Despite jurisdictional challenges, COMELEC’s retroactive nullification due to judicial impropriety and insufficient election protest grounds was permissible.
3. **Grave Abuse Affirmed:** The court recognized that Barillo’s conduct, including unauthorized legal representation, constituted grave abuse though insufficient for gross misconduct.
4. **Finality Argument Dismissed:** The practical legal effect had dissipated due to the term expiration of the contested barangay office.
**Doctrine:**
– **Public Officer as Nominee:** Judges or public officials should not independently contest higher judicial or administrative decisions unless directly aggrieved or ordered by the presiding appellate body.
– **Jurisdiction in Election Matters:** Despite procedural technicalities, higher bodies like COMELEC can override erstwhile decisions if grave discretion is manifest, ensuring fairness and due process.
**Class Notes:**
– **Grave Abuse of Discretion:** A public official seriously overstepping boundaries without legal basis can result in challenging their decisions through certiorari, especially in election disputes.
– **Judicial Independence:** A judge must uphold integrity and avoid direct involvement in appeals processes beyond their juridical acts to maintain impartiality.
– **Suspension of Lawyers:** Resumption of practice post-suspension is contingent on receiving official court reinstatement, setting precedent for courts ensuring representation correctness.
**Historical Background:**
Arising from the barangay elections synchronized nationally under Republic Act No. 9164 and later affected by Republic Act No. 9340, this case captures a microcosm of wider electoral dynamics, emphasizing judicial oversight in maintaining integrity, especially in localized election contexts—highlighting complexities in judiciary roles amid political processes.
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