Court's power to review electoral tribunals

It is hornbook principle that the Supreme Court's jurisdiction to review decisions and orders of electoral tribunals is exercised only upon a showing of grave abuse of discretion committed by the tribunal. Absent such grave abuse of discretion, this Court shall not interfere with the electoral tribunal's exercise of its discretion or jurisdiction.[1] Grave abuse of discretion has been defined in Villarosa v. House of Representatives Electoral Tribunal[2] as follows:
Grave abuse of discretion implies such capricious and whimsical exercise of judgment as is equivalent to lack of jurisdiction; or, in other words, where the power is exercised in an arbitrary manner by reason of passion or personal hostility. It must be so patent and gross as to amount to an evasion of positive duty or to a virtual refusal to perform the duty enjoined or to act at all in contemplation of law.[3]

[1] Abubakar v. House of Representatives Electoral Tribunal, G.R. Nos. 173310 and 173609, March 7, 2007, 517 SCRA 762, 776; Torres v. House of Representatives Electoral Tribunal, G.R. No. 144491, February 6, 2001, 351 SCRA 312, 326-327.

[2] G.R. Nos. 143351 and 144129, September 14, 2000, 340 SCRA 396.

[3] Id. at 413. (Emphasis supplied.)

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