Facts:

The case involves Mauro G. Agda as the petitioner and Crispin N. San Juan along with Honorable Judge Buenaventura J. Guerrero of the Court of First Instance of Rizal, Branch XXIV, as respondents. The events leading to this case began with the general elections held on November 8, 1971, where both Agda and San Juan were candidates for the position of municipal councilor in their municipality. Following the elections, on November 16, 1971, the municipal board of canvassers announced the winning candidates but refrained from proclaiming the winner for the 8th councilor position due to a resolution from the Commission on Elections dated November 12, 1971. Subsequently, on December 14, 1971, Agda was proclaimed the winner for the 8th councilor position, having received 2,849 votes compared to San Juan's 2,848 votes. However, on December 24, 1971, San Juan filed an election protest in the respondent court, challenging the accuracy of the vote count and the election returns from...

Facts:

Background of the Case

• The petition arises from the municipal elections held on November 8, 1971, in which both petitioner Mauro G. Agda and private respondent Crispin N. San Juan vied for a municipal councilor position.
• The municipal board of canvassers proclaimed the winning candidates on November 16, 1971, but withheld the proclamation for the contested 8th slot in the council pending further resolution by the Commission on Elections pursuant to its November 12, 1971 resolution.

Proclamation and Contestation

• On December 14, 1971, the contested election for the 8th councilor position was resolved when petitioner was proclaimed the winner with a total of 2,849 votes, narrowly edging private respondent by one vote, who obtained 2,848 votes.
• Following the issuance of the proclamation, private respondent filed an election protest on December 24, 1971, challenging the accuracy of the vote count, canvass, and election returns specifically in ten designated precincts.

Counter-Protest and Revision Proceedings

• In response to the protest, petitioner filed a counter-protest, contesting the election results in fourteen different precincts.
• The respondent court, in an effort to resolve the disputes, appointed two committees:
• One committee appointed by the court.
• Two committees subsequently appointed by the respective parties (petitioner and private respondent).
• These committees were tasked with the revision of the ballots and election documents in the contested precincts; their function was to perform an actual and physical recount of votes while segregating those considered disputed.

Decision of the Lower Court and Supreme Court Involvement

• After the comprehensive revision and trial conducted by the respondent court, a judgment was rendered favoring the private respondent, thereby affirming his election despite the one-vote margin.
• Petitioner Mauro G. Agda filed a petition for review on certiorari before the Supreme Court, challenging the trial court’s appreciation and evaluation of the disputed ballots.
• It is noted that by the time the petition reached the Supreme Court, the case had become moot due to the subsequent election for municipal officials on January 30, 1980, which rendered the term of the proclaimed winners from 1971 expired.

Issue:

Whether the trial court erred in the appreciation and evaluation of the disputed ballots during the recount conducted by the two committees.

• The petitioner argued that the revision process did not correctly reflect the accurate vote count in the contested precincts.
• The central contention was that the one-vote difference might have been the result of an erroneous counting process.

The impact of the case’s mootness on the adjudication of the merits of the election protest.

• Given that a new election was held on January 30, 1980, the issues raised might no longer have any practical or legal effect, thereby rendering the petition academic and without a current controversy.

The broader question concerning the proper procedure for the review and revision of ballots and the limitations imposed by election timelines.

• The issue involves whether the judicial intervention in election disputes should be entertained when the electoral mandate has lapsed.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)