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RONALD ALLAN POE v. GLORIA MACAPAGAL-ARROYO

FACTS:

This case involves an election protest filed by Fernando Poe Jr. (FPJ) against Gloria Macapagal Arroyo (GMA) regarding the May 10, 2004 Presidential Elections in the Philippines. FPJ filed the protest before the Electoral Tribunal but passed away during the proceedings. His widow, Jesusa Sonora Poe (Mrs. FPJ), filed a manifestation and urgent petition/motion to intervene as a substitute for her deceased husband. Mrs. FPJ argued that there is an urgent need for her to continue and substitute for her late husband to determine the true will of the electorate. GMA countered that the widow is not the proper party to replace the deceased protestant and that no such right survives the husband to file an election protest. GMA also argued that Mrs. FPJ did not receive the 2nd or 3rd highest votes for the presidency and that the Tribunal only has jurisdiction over election protests, not actions of surviving spouses. GMA further claimed that the public interest in the protest dies with the protestant, and an adversarial nature of the case cannot be maintained when one of the parties dies.

ISSUES:

  1. The main issue in this case is whether the widow can substitute for the protestant who died during the pendency of the protest case.

  2. Whether the widow of the protestant is a real party in interest who can intervene and substitute for the deceased protestant in an election protest.

RULING:

  1. The widow cannot substitute for the protestant who died during the pendency of the protest case. Substitution in election contests is not allowed as a public office is personal to the public officer and not a property transmissible to the heirs upon death. This rule has been consistently applied by the court in previous cases involving substitution by the widow or heirs of a deceased protestant. While the death of the protestant does not necessarily abate the pending action, substitution by the widow or heirs is not allowed as they are not the real parties in interest.

  2. The Court denied the motion for intervention and substitution filed by the widow of the protestant on the ground that she is not a real party in interest. The Court held that a real party in interest is the party who would be benefited or injured by the judgment and who is entitled to the avails of the suit. The Court further explained that the widow, who herself denies any claim to the office of President, will not immediately and directly benefit from the outcome of the protest. The Court also emphasized that if persons who are not real parties in the action could be allowed to intervene, the proceedings would be unnecessarily complicated, expensive, and interminable, which is not the policy of the law. Consequently, the Court dismissed the election protest.

PRINCIPLES:

  • In a presidential election protest, only the registered candidate who received the second or third highest number of votes may contest the election.

  • Substitution in election contests is not allowed as a public office is personal to the public officer and not a property transmissible to the heirs upon death.

  • The death of the protestant does not necessarily abate the pending action, but substitution by the widow or heirs is not allowed as they are not the real parties in interest.

  • Intervention is allowed in an election protest only by a real party in interest, who is the party who would be benefited or injured by the judgment and who is entitled to the avails of the suit.

  • The interest of an intervenor in an election protest must be of such direct and immediate character that the intervenor will either gain or lose by the effect of the judgment.

  • The existing strict limitations on intervention and substitution under the law and the rules in an election protest should be abided by to avoid unnecessary complications, expenses, and prolongation of the proceedings.