**Facts:**
1. **May 14, 2007:** Joselito R. Mendoza (petitioner) and Roberto M. Pagdanganan (respondent) contended for the gubernatorial position of Bulacan.
2. **Post-Election:** Mendoza was proclaimed the winner and assumed office.
3. **Election Protest:** Pagdanganan filed a protest with the COMELEC, which was docketed as EPC No. 2007-44 and assigned to the Second Division. Revision of ballots started.
4. **COMELEC Proceedings:** The proceedings included revision and presentation of evidence, formal offers, and submission of memoranda from both parties. The case was submitted for resolution.
5. **March 2, 2009:** COMELEC transferred the Bulacan ballot boxes to the Senate Electoral Tribunal (SET) for an unrelated protest.
6. **Suspension Motion:** Mendoza moved to suspend proceedings due to the ballot transfer. The COMELEC Second Division denied this on April 29 and reaffirmed the decision on May 26, 2009.
7. **June 2009:** Mendoza’s attorney sought confirmation of alleged unnotified proceedings from SET Secretary, who confirmed coordinated proceedings were being held at SET premises.
8. **Petition for Certiorari:** Mendoza filed a petition citing due process violations because of the lack of notice for the proceedings at SET premises. He also argued that COMELEC exceeded its jurisdiction by appreciating ballots outside their custody and premises.
**Issues:**
1. **Due Process Violation:** Whether the COMELEC violated Mendoza’s due process rights by conducting proceedings without his notice or participation after the case’s submission for resolution.
2. **Jurisdiction and Proceedings:** Whether COMELEC’s appreciation of ballots outside its premises and custody amounted to a grave abuse of discretion or excess of jurisdiction.
**Court’s Decision:**
– **Due Process Violation:**
– The petitioner fully participated in preliminary stages by revising ballots, presenting evidence, and submitting memoranda.
– No adversarial proceedings requiring notice occurred post-submission; only internal deliberations by COMELEC took place at the SET premises, consistent with judicial deliberation practices which need confidentiality.
– Held: No due process violation as no new proceedings occurred requiring notice.
– **Jurisdiction and Proceedings:**
– COMELEC retained jurisdiction despite the ballot custody transfer to SET, adhering to the “order of preference” concerning the retention and revision of ballots established in COMELEC Resolution No. 2812.
– Coordination and procedural discretion are permitted under the constitutional and regulatory framework to expedite election cases. Thus, appreciation of ballots at SET premises is within COMELEC’s broad discretionary power.
– Held: COMELEC’s action and decision-making process were legitimate and not an abuse of discretion.
**Doctrine:**
– Judicial/Quasi-Judicial Bodies’ Internal Deliberations: Internal and confidential deliberations post-submission for decision are procedural norms that do not necessitate party notice.
– Adherence to Jurisdiction and Coordination between Tribunals: COMELEC and similar quasi-judicial bodies can exercise discretion in jurisdictional overlaps by coordinating with respective tribunals to expedite case resolutions.
**Class Notes:**
1. **Due Process in Quasi-Judicial Proceedings:**
– Right to be heard encompasses presenting one’s case and rebutting opponent’s submissions.
– Internal deliberations post-submission are not adversarial stages and do not require party participation or notification.
2. **Jurisdiction and Authority:**
– An ongoing jurisdiction cannot be ousted by the temporary transfer of evidence/materials to another tribunal.
– Coordination among tribunals, even outside explicit procedural rules, valid when aimed at efficient case adjudication.
3. **Legal Provisions:**
– Section 4, COMELEC Rules of Procedure: Allows COMELEC broad means to effectuate its powers/jurisdiction.
– COMELEC Resolution No. 2812: Prescribes prioritization for access and revision of ballots by different electoral bodies.
**Historical Background:**
This case fits within the Philippine electoral history of ensuring transparency and fairness in election disputes post-Marcos dictatorship, reflecting newer constitutional frameworks empowering COMELEC with broader administrative, quasi-judicial duties since the 1987 Constitution, moving from solely judicial functions to complex, multi-faceted roles in electoral regulation. This specific ruling underscores the judiciary’s trust in COMELEC’s procedural discretion in overlapping jurisdictions with other electoral tribunals like the SET.
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