Principle 3: Effective Investigation to prosecute those cases as necessary.296 The Commission on Elections also exercises exclusive original jurisdiction for investigating and adjudicating all contests relating to elections, including returns and qualifications for elective regional, provincial, and city officials.297 Likewise, in Liberia, the National Elections Commission has original jurisdiction for reviewing all disputes relating to results of all elections.298 Systems that provide concurrent jurisdiction or that permit complainants to choose among investigative bodies to which they can file complaints run the risk of duplicating investigations and stoking institutional rivalry and forum shopping.299 In Lebanon, for example, several bodies have concurrent jurisdiction over investigations300 and the absence of guidelines on the division of power among institutions produces conflicting interpretations of similar factual situations, incentivizing claimants to seek out the most favorable forum and thereby undermining the legitimacy of both investigation and adjudication.301 In the seminal judgment, Aliyev v. Azerbaijan, the European Court of Human Rights found that, in part, the lack of clarity as to which institutions should receive and consider complaints prevented effective and timely resolution of electoral disputes.302 While the Azerbaijani Election Code envisages that most complaints are filed with the localized Constituency Election Commissions (ConECs), the law also allows for complaints to be lodged with the Central Election Commission (CEC), without any delineation as to the subject-matter 296 Const. (1987), art. IX-C, sec. 2 (Phil.); Omnibus Election Code, B.P.Blg. 881, art. VII, sec. 265 (Phil.); COMELEC Rules of Procedure, Rule 34 § 1 (Phil.). 297 Const. (1987), art. IX-C, sec. 2 (Phil.). 298 Republic of Liberia, Elections Law of 2004 § 2.9(q) (2004). 299 Robert Dahl, Electoral Complaint Adjudication and Dispute Resolution: Key Issues and Guiding Principles, Remarks at the 2008 General Assembly of the Association of Asian Election Authorities (July 22, 2008) 300 See GUARDE, supra note 1, at 24–25.; Gaelle Deriaz, The 2009 Mechanisms for Handling Electoral Complaints and Appeals in Lebanon 16 (2009) (The Lebanese complaints adjudication process involves several entities that share jurisdiction over specific elections issues. Three electoral management bodies have authority process complaints: the Ministry of Interior and Municipalities, the Supervisory Commission on the Electoral Campaign, and the Registration Committees and Higher Registration Committees. Electoral Courts also handle electoral matters and follow their separate procedures to determine subject matter jurisdiction.). 301 Autheman, supra note 52. 302 Namat Aliyev v. Azerbaijan, App. No. 18705/06 Eur. Ct. H.R. ¶ 55 (2010), http://hudoc.echr.coe.int/sites/eng/pages/ search.‌aspx?i‌=001-98187. 95