Facts:

The case revolves around Arsenio Alvarez, the petitioner, and the Commission on Elections (COMELEC) along with La Rainne Abad-Sarmiento, the respondent. The events leading to this case transpired after the Barangay elections held on May 12, 1997, in Barangay Doña Aurora, Quezon City. Alvarez was initially declared the duly elected Punong Barangay, receiving 590 votes against Abad-Sarmiento's 585. Following the elections, Abad-Sarmiento contested the results through an election protest, alleging irregularities, specifically misreading and misappreciation of ballots by the Board of Election Inspectors. Subsequently, the Metropolitan Trial Court, upon reviewing the case, ordered a recount of ballots from ten contested precincts. The recount revealed that Abad-Sarmiento had actually won with 596 votes to Alvarez's 550.

Alvarez appealed this decision to the Second Division of the COMELEC, which ruled in favor of Abad-Sarmiento. In her favor, Abad-Sarmiento filed a Motion for

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Facts:

Background of the Election Controversy

• On May 12, 1997, petitioner Arseniio Alvarez was proclaimed the duly elected Punong Barangay of Barangay DoAa Aurora, Quezon City with 590 votes, defeating private respondent La Rainne Abad-Sarmiento who obtained 585 votes.
• An election protest was filed by the private respondent alleging irregularities such as misreading and misappreciation of ballots by the Board of Election Inspectors.

Recount and Lower Court Decision

• After the issues were joined and petitioner answered, the Metropolitan Trial Court ordered a reopening and recounting of ballots in ten contested precincts.
• The recount resulted in a reversal of the initial findings: private respondent now obtained 596 votes while petitioner’s vote count fell to 550.
• Consequently, the Metropolitan Trial Court issued a decision declaring private respondent as the duly elected Punong Barangay and directed petitioner to vacate and turnover the office upon finality of the resolution.

COMELEC’s Involvement

• On appeal, the Second Division of the Commission on Elections (COMELEC) ruled in favor of private respondent, thereby affirming the lower court’s decision.
• Simultaneously, a Motion for Execution pending appeal filed by private respondent was granted while petitioner’s Motion for Reconsideration was denied by the COMELEC En Banc.
• The COMELEC En Banc promulgated its resolution on April 4, 2000, which included:
• Denial of petitioner’s Motion for Reconsideration.
• Affirmation of the Second Division’s decision.
• Granting of the Motion for Execution pending appeal.

Allegations Raised by the Petitioner

• Petitioner alleged grave abuse of discretion by COMELEC on three grounds:
• Failure to give preferential disposition to the election case, which he argued was mandated by Section 3, Article IX-C of the 1987 Constitution and Section 257 of the Omnibus Election Code.
• Premature execution of the resolution via granting the Motion for Execution pending appeal, despite the appeal not being pending at the time of resolution.
• Misinterpretation of the Constitutional provision regarding the finality and executory nature of decisions on election contests involving municipal and barangay officials.
• Petitioner emphasized the alleged delay (noted as four months and four days past the prescribed deadline) and the procedural improprieties in handling the case.

Issue:

Alleged Violation of Preferential Disposition

• Did the COMELEC abuse its discretion by not treating the election case with the urgency required under Section 3, Article IX-C of the 1987 Constitution and Section 257 of the Omnibus Election Code?

Granting of Execution Pending Appeal

• Was it proper for the COMELEC En Banc to grant the Motion for Execution pending appeal when, according to petitioner, the appeal was no longer pending and the motion had become obsolete?

Interpretation of Constitutional Provisions

• Did the COMELEC misinterpret Section 2(2), second paragraph, Article IX-C of the 1987 Constitution regarding the appealability of factual findings in election contests involving municipal and barangay officials?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)