Bondoc vs. Pineda, 201 SCRA 792, G.R. No.

97710, 26 Sept 1991

Facts:
In the elections held on May 11, 1987, Marciano Pineda of the LDP and
EmigdioBondocof the NP werecandidates for the position of Representative for the
Fourth District of Pampanga. Pineda was proclaimed winner.Bondoc filed a protest in
the House of Representatives Electoral Tribunal (HRET), which is composed of 9
members,3 of whom are Justices of the SC and the remaining 6 are members of the
House of Representatives (5 membersbelong to the LDP and 1 member is from
the NP). Thereafter, a decision had been reached in which Bondoc
won over Pineda. Congressman Camasura of the LDP voted with the SC Justices and
Congressman Cerilles of the NP toproclaim Bondoc the winner of the contest.On the
eve of the promulgation of the Bondoc decision, Congressman Camasura received a
letter informing him thathe was already expelled from the LDP for allegedly
helping to organize the Partido Pilipino of Eduardo Cojuangco and for allegedly
inviting LDP members in Davao Del Sur to join said political party. On the day of the
promulgation of thedecision, the Chairman of HRET received a letter informing the
Tribunal that on the basis of the letter from the LDP,the House of Representatives
decided to withdraw the nomination and rescind the election of CongressmanCamasura
to the HRET.
Issue:
Whether or not the House of Representatives, at the request of the dominant political
party therein, maychange that partys representation in the HRET to thwart the
promulgation of a decision freely reached by the tribunalin an election
contest pending therein
Held:
The purpose of the constitutional convention creating the Electoral Commission was to
provide an independentand impartial tribunal for the determination of contests to
legislative office, devoid of partisan consideration. As judges, the members of the
tribunal must be non-partisan. They must discharge their functions with
completedetachment, impartiality and independence even independence from
the political party to which they belong. Hence, disloyalty to party and breach of
party discipline are not valid grounds for the expulsion of a member of the tribunal.
Inexpelling Congressman Camasura from the HRET for having cast a conscience vote
in favor of Bondoc, basedstrictly on the result of the examination and appreciation of the
ballots and the recount of the votes by the tribunal, theHouse of Representatives
committed a grave abuse of discretion, an injustice and a violation of the Constitution.
Itsresolution of expulsion against Congressman Camasura is, therefore, null and
void. Another reason for the nullity of the expulsion resolution of the House of
Representatives is that it violatesCongressman Camasuras right to security of tenure.
Members of the HRET, as sole judge of congressional electioncontests, are entitled to
security of tenure just as members of the Judiciary enjoy security of tenure under
theConstitution. Therefore, membership in the HRET may not be terminated except for

a just cause, such as, theexpiration of the members congressional term of office, his
death, permanent disability, resignation from the politicalparty he represents in the
tribunal, formal affiliation with another political party or removal for other valid cause.
Amember may not be expelled by the House of Representatives for party disloyalty,
short of proof that he has formallyaffiliated with another