Title
Aleman vs. Genato
Case
G.R. No. 63510
Decision Date
Dec 26, 1984
The Court ruled to order a recount of ballots, finding the deduction of votes from alleged flying voters unjustified and preventing the judgment's implementation.
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Case Digest (G.R. No. 63510)

Facts:

  • Aurelio Aleman (petitioner) and Nicanor Caramba (private respondent) were candidates for Barangay Captain in Mialen, Clarin, Misamis Occidental during the May 17, 1982 elections.
  • Aleman was proclaimed the winner with 393 votes, while Caramba received 358 votes, resulting in a 35-vote margin.
  • On May 24, 1982, Caramba filed an election protest, claiming non-registered voters voted and that some ballots were miscounted in Aleman's favor.
  • Aleman denied the allegations, asserting that all voters were registered and verified by the Commission on Elections (COMELEC).
  • The Municipal Circuit Court invalidated 12 of Aleman's votes, reducing his total to 381, but he still led by 23 votes.
  • Caramba appealed, and on December 27, 1982, the Court of First Instance invalidated an additional 26 votes from Aleman's tally, declaring Caramba the winner with 358 votes.
  • Aleman contested the deductions, arguing there was no evidence for the invalidated votes.
  • Judge Glicerio V. Carriaga, Jr. denied Aleman's motion for reconsideration, relying on the presumption of thorough review by the retired Judge Melecio Genato.
  • The Supreme Court issued a Temporary Restraining Order to prevent Caramba from assuming office pending resolution.
  • The Supreme Court decided to recount the ballots to determine the true will of the electorate.

Issue:

  • (Unlock)

Ruling:

  • Yes, the Court of First Instance erred in invalidating the votes based on the claims presented.
  • No, there was insufficient evidence to justify the deductions from Aleman's total votes.
  • ...(Unlock)

Ratio:

  • The Supreme Court found that the Court of First Instance made errors in its judgment r...continue reading

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