Electoral tribunal's procedural rules
In Hofer v. House of Representatives Electoral Tribunal,[1] a case
that is closely analogous to the instant petition, the Court emphasized
that "[p]rocedural rules in election cases are designed to achieve not
only a correct but also
an expeditious determination of the popular will of
the electorate."[2] Thus, the time limit set by the rules is not
something to be taken lightly, for it was stressed in the same case that "the
observance of the HRET Rules in conjunction with our own Rules of Court, must
be taken seriously."[3] Quoting Baltazar v. Commission of
Elections,[4] The Court reiterated in Hofer[5] that:
Basing on the foregoing legal arguments, the Supreme Court found that the
House of Representatives Electoral Tribunal (HRTE) acted in the best interest
of the electorate, ensuring the determination of the latter's will within a
reasonable time. In sum, the High Court said that there was absolutely nothing
in the case that would justify a finding that the HRET gravely abused its
discretion by not granting petitioner an extension of time to present
additional evidence and formally offer the same.[7]
By their very nature and given the public interest involved in the determination of the results of an election, the controversies arising from the canvass must be resolved speedily, otherwise the will of the electorate would be frustrated. And the delay brought about by the tactics resorted to by petitioner is precisely the very evil sought to be prevented by election statutes and controlling case law on the matter.[6]

[1] G.R. No. 158833, May 12, 2004, 428 SCRA 383.
[2] Id.
[3] Id. at 386.
[4] G.R. No. 140158, January 29, 2001, 350 SCRA 518.
[5] Supra note 1.
[6] Baltazar v. Commission on Elections, supra note 1, at 387.
[7] G.R. No. 190067, March 09, 2010.