Facts:

The case involves Espirita N. Acosta as the petitioner and the Commission on Elections (COMELEC), Judge Genoveva Coching Maramba in her capacity as Presiding Judge of the Municipal Circuit Trial Court of San Fabian/San Jacinto, Pangasinan, and Raymundo I. Rivera as the respondents. The events leading to this case began with the barangay elections held on May 12, 1997, in Barangay Sobol, San Fabian, Pangasinan, where Acosta was declared the duly elected Punong Barangay, winning by a margin of four votes over Rivera. On May 15, 1997, Rivera filed an election protest in the Municipal Circuit Trial Court, claiming that the votes cast for him were not properly accounted for due to various errors in the counting process, including misreading and mistallying of ballots. The court summoned Acosta, who requested additional time to file an answer, but this request was denied on May 21, 1997, when the court deemed the protest sufficient for a recount. The court ordered the COMELEC Elect...

Facts:

Background of the Case

• The case involves candidates running for Punong Barangay in Barangay Sobol, San Fabian, Pangasinan during the May 12, 1997, barangay elections.
• Petitioner's winning margin was four votes, resulting in his proclamation as the duly elected Punong Barangay.

Electoral Dispute and the Election Protest

• On May 15, 1997, Raymundo I. Rivera filed an election protest with the Municipal Circuit Trial Court (MCTC) of San Fabian-San Jacinto.
• The protest alleged that in certain precincts (No. 22-A, No. 22-A-1, No. 22-B, and No. 22-B-1):

- Votes were not duly or properly accounted for. - There were instances of misreading, non-reading, mistallying, and misappreciation of ballots or votes.

Proceedings in the Lower Court

• On May 16, 1997, the court a quo summoned petitioner Acosta in relation to the protest.
• On May 19, 1997, Acosta filed a Motion for Time to File an Answer, which was subsequently denied on May 21, 1997, by the court.
• The court concluded that the election protest was sufficient in form and substance.
• The same order directed the COMELEC Election Registrar and/or Municipal Treasurer to produce election documents and ballot boxes for further inspection and revision of ballots.

Petitions Filed with the COMELEC

• On May 29, 1997, petitioner Acosta filed a petition for certiorari and prohibition with COMELEC, seeking a temporary restraining order and/or writ of preliminary injunction against the MCTC’s order dated May 21, 1997.
• The petition was docketed as SPR No. 13-97.
• On May 30, 1997, the lower court rendered a decision nullifying petitioner’s proclamation due to the finding that Rivera had secured 408 votes while petitioner had 405 votes.
• Acosta then filed a notice of appeal on June 11, 1997, which was granted by the respondent judge, assigning it as UNDK No. 5-97 before COMELEC.

COMELEC’s Resolution and Subsequent Controversy

• On December 2, 1997, the COMELEC en banc issued a resolution in SPR No. 13-97:

- Dismissing the petition on grounds of lack of merit. - Affirming both:

Alleged Violations and Claimed Defects

• The petitioner contended that the COMELEC exceeded its jurisdiction by affirming a decision (May 30, 1997) which was not the subject matter of SPR No. 13-97.
• It was argued that:

- The appealed decision (UNDK No. 5-97) was not consolidated with the petition, - The appeal was still pending (undocketed) at the time of COMELEC’s resolution. - The need for the court/tribunal to have proper judicial authority. - Jurisdiction over the parties involved. - The necessity for the parties to be allowed to present evidence. - That such evidence must be duly considered before a decision is rendered.

Issue:

Whether the COMELEC exceeded its jurisdiction by affirming the trial court’s decision pertaining to the election protest and subsequent appeal.

• The question centers on the propriety of COMELEC’s resolution in SPR No. 13-97 which, while addressing a lower court’s interlocutory order, also later affirmed a decision (May 30, 1997) that was the subject of an unresolved appeal (UNDK No. 5-97).

Whether the decision rendered by the lower court, and its subsequent affirmation by COMELEC, compromised due process requirements.

• Specifically, whether the parties were afforded the necessary opportunity to adduce evidence and whether the proper judicial authority was exercised in resolving the election protest.
• Whether the appellate procedure followed met constitutional and procedural safeguards when evidence was still pending submission.

• Whether the COMELEC’s resolution contravened the constitutional mandate under Article IX-C, Section 3 of the Constitution, which requires election cases to be heard and decided “in division” except for motions for reconsideration, which are decided en banc.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)