JEREMIAS V. ESTEVES v. RENE V. SARMIENTO

FACTS:

On 13 March 2008, the petitioner filed a motion for reconsideration before the COMELEC (First Division), seeking a reversal of its earlier decision dismissing his petition for disqualification. However, the said motion was denied by the COMELEC (Second Division) through a Resolution dated 16 May 2008. Consequently, the petitioner filed the present petition.

ISSUES:

  1. Whether the election protest filed by petitioner complied with the requirements of Section 11(f), Rule 2 of A.M. No. 07-4-15-SC.

  2. Whether the RTC erred in denying private respondent's motion to dismiss.

RULING:

  1. Yes, the election protest failed to comply with the requirements of Section 11(f), Rule 2 of A.M. No. 07-4-15-SC. The Court of Appeals (COMELEC) nullified the order of the RTC and dismissed the election protest filed by petitioner.

  2. No, the RTC did not err in denying private respondent's motion to dismiss.

PRINCIPLES:

  • Election protests must comply with the requirements established by law or administrative rules in order to be considered valid.

  • It is within the authority of the RTC to deny a motion to dismiss if it finds that there is no merit to the grounds raised by the moving party.