Facts:

The case involves Arnulfo Abaya as the petitioner and Eric Singson as the private respondent, with Judge Castor Z. Concepcion serving as the respondent judge. The events leading to this case began with the general election held on January 30, 1980, in the Municipality of Candon, Ilocos Sur, where Abaya and Singson were candidates for mayor. Following the election, the Municipal Board of Canvassers proclaimed Singson as the winner based on the canvassed returns from 68 voting centers. On February 9, 1980, Abaya filed a "Petition of Protest" contesting the election results, alleging various irregularities, including that votes cast for him were either not counted or counted for Singson, and that invalid ballots were counted in favor of Singson.

After the issues were joined, Judge Concepcion ordered the production of ballot boxes and election documents for examination. Following the recount of ballots, Abaya sought to examine the registry lists of voters and other el...

Facts:

The case involves the mayoral election held on January 30, 1980, in Candon, Ilocos Sur, where Arnulfo Abaya (the protestant candidate) contested the proclamation of Eric Singson (the protestee candidate) as the winner. After the canvassing of returns from 68 voting centers and the initial reopening and examination of ballot boxes, Abaya filed a protest contesting various alleged irregularities in the election returns. Specific allegations included the miscounting or manipulation of ballots, such as substitute voting and improper rejection of certain ballots. In response, Judge Castor Z. Concepcion, who was presiding over the case in the Court of First Instance of Ilocos Sur, initially allowed an examination of documents (registry lists of voters, voting records, and related election paraphernalia) only in six specified voting centers where substitute voting was alleged, thus curtailing further inspection initially sought by Abaya. Subsequently, Abaya moved for the examination of similar documents in the remaining 62 voting centers. Judge Concepcion denied this further inspection on the grounds that the additional examination was not warranted by the protest’s allegations and might lead to an unstructured "fishing expedition." Abaya then resorted to a special civil action for mandamus and prohibition with an accompanying petition for a temporary restraining order before the Commission on Elections was certified the petition to the Court, which ultimately led to the present issue on whether the trial court’s discretionary denial of further document examination was proper.

Issue:

1. Whether the trial court's enunciation of its discretion in allowing or denying the examination of election documents constitutes a ministerial duty that can be compelled through a petition for mandamus and prohibition.
2. Whether Judge Concepcion abused his discretion in limiting the examination of the election documents to only the six voting centers with specific allegations, thereby denying Abaya access to the records from the remaining 62 voting centers.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)