Case Digest (G.R. No. L-2078)
Facts:
The case involves Pacito Abrea as the petitioner and appellant, and Isabelo A. Lloren as the respondent and appellee. The events took place during the general elections held on November 11, 1947, in Inopacan, Leyte, where both candidates vied for the position of municipal mayor. Isabelo A. Lloren submitted a certificate of candidacy that included various names he was known by, including Isabelo A. Lloren, Isabelo Lloren Abrea, and notably, the nickname "Beloy." After the election, the municipal board of canvassers proclaimed Lloren as the municipal-mayor-elect, having received 1,010 votes, which was 198 votes more than Abrea's total of 812 votes.
Abrea contested the election results, focusing on the claim that 417 votes cast for "Beloy" should not have been counted in favor of Lloren. During the trial, it was revealed that 517 votes were cast for "Beloy," 77 for "Biloy," and 8 for "Belog." The trial court determined tha...
Case Digest (G.R. No. L-2078)
Facts:
- Election Context: In the general elections of November 11, 1947, Pacito Abrea (appellant) and Isabelo A. Lloren (appellee) were candidates for the office of municipal mayor of Inopacan, Leyte.
- Certificate of Candidacy: Isabelo Lloren stated in his certificate of candidacy that he was also known by various names, including Isabelo A. Lloren, Isabelo Lloren Abrea, Beloy Abrea, Beloy Lloren, I. Lloren, I. Abrea, Loy Lloren, and Loy Abrea.
- Election Results: The municipal board of canvassers proclaimed Isabelo Lloren as the municipal-mayor-elect with 1,010 votes, giving him a majority of 198 votes over Pacito Abrea, who obtained 812 votes.
- Protest by Abrea: Pacito Abrea protested the election on four grounds, but only one was relied upon in the appeal: that 417 votes cast in favor of "Beloy" were credited to Isabelo Lloren.
- Ballot Examination: During the trial, it was found that 517 votes were cast for "Beloy," 77 for "Biloy," and 8 for "Belog." The trial court found that Isabelo Lloren was popularly known by the nickname "Beloy" or "Biloy" in Inopacan and that no other candidate for mayor was known by that nickname.
- Trial Court Decision: The trial court confirmed the proclamation of Isabelo Lloren as the municipal-mayor-elect, ruling that the votes for "Beloy," "Biloy," and "Belog" were validly counted in his favor.
Issue:
- Validity of Nickname Votes: Whether the 602 ballots cast for "Beloy," "Biloy," and "Belog" should be considered valid votes for Isabelo Lloren, despite only his nickname being written on the ballots.
- Application of Election Code: Whether the provisions of the Revised Election Code (Republic Act No. 180) support the counting of votes where only a candidate's nickname appears.
- Admissibility of Evidence: Whether the trial court erred in admitting evidence to prove that Isabelo Lloren was popularly known by the nickname "Beloy" or "Biloy."
- Recount of Votes: Whether the trial court erred in not ordering a recount of all votes cast for both candidates.
Ruling:
The Supreme Court affirmed the decision of the trial court, holding that:
- The 602 ballots cast for "Beloy," "Biloy," and "Belog" were validly counted in favor of Isabelo Lloren because:
- The nickname "Beloy" or "Biloy" is a derivative or contraction of his Christian name "Isabelo."
- He was popularly and commonly known by that nickname in the municipality of Inopacan.
- There was no other candidate for mayor with the same nickname.
- The Revised Election Code does not invalidate votes where only a candidate's nickname appears, provided the nickname sufficiently identifies the candidate.
- The trial court did not err in admitting evidence to prove that Isabelo Lloren was popularly known by his nickname, as this evidence was necessary to establish his identity.
- The trial court acted properly in limiting the inquiry to the validity of the 602 ballots, as the protest was specifically focused on those votes.
Ratio:
- (Unlock)