Case Digest (G.R. No. 35857)
Facts:
The case of Gaudencio Aquino vs. Crispin Calabia and Zacarias Sahagun (G.R. No. 35857) was decided on August 26, 1931. The dispute arose from the municipal elections held in San Pablo, Laguna, where Gaudencio Aquino contested the election results that proclaimed Crispin Calabia as the elected municipal president. Aquino alleged that he received 1,697 votes, while Calabia received 1,683 votes, thus claiming he should have been declared the winner. However, the municipal board of canvassers allegedly reduced Aquino's votes from 1,697 to 1,675, allowing Calabia to be proclaimed the winner by a margin of 8 votes. Aquino contended that this reduction was fraudulent and based on falsified election returns, particularly from precinct No. 20, where it was claimed that he received only 31 votes instead of the actual 53. The lower court dismissed Aquino's original protest on the grounds that it did not sufficiently challenge the election results and that the amended protest w...
Case Digest (G.R. No. 35857)
Facts:
Election Results and Protest:
- Gaudencio Aquino (contestant) and Crispin Calabia and Zacarias Sahagun (contestees) were candidates in the municipal election of San Pablo, Laguna.
- According to the election results, Aquino received 1,697 votes, Calabia received 1,683 votes, and Sahagun received 1,281 votes.
- Aquino should have been proclaimed the winner with a 14-vote lead over Calabia.
Allegations of Fraud:
- Aquino alleged that the municipal board of canvassers fraudulently reduced his votes from 1,697 to 1,675 by subtracting 22 votes, enabling Calabia to be proclaimed the winner by an 8-vote margin.
- The fraud involved the use of a falsified election return for Precinct No. 20, where Aquino’s votes were reduced from 53 to 31.
- The election inspectors of Precinct No. 20 had informed the board of canvassers about the falsification and presented authentic returns, tally sheets, and certificates showing Aquino’s actual votes.
Legal Proceedings:
- Aquino filed an election protest on June 5, 1931, challenging the proclamation and the fraudulent actions of the board of canvassers.
- The lower court dismissed the protest, stating that courts cannot revise the proclamation or the proceedings of the board of canvassers.
- Aquino filed an amended protest on June 23, 1931, which the court also dismissed as it was filed after the 15-day period following the proclamation.
Issue:
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Ruling:
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Ratio:
Purpose of Election Contests:
- The primary purpose of an election contest is to correct the canvass and declare the rightful winner. Courts have the authority to examine ballots and election documents to determine the true results of an election.
Grounds for Election Protests:
- Election protests can be based on grounds such as ineligibility of the winning candidate, non-compliance with mandatory election procedures, or fraud in the counting of votes. Aquino’s protest fell under the third category, as it alleged fraud in the canvassing process.
Amendments to Protests:
- Amendments to election protests that do not introduce new facts or fundamentally alter the nature of the protest should be allowed, even if filed after the statutory period. The amended protest in this case was consistent with the original protest and did not constitute a new cause of action.
Jurisdiction Over Election Contests:
- Courts have exclusive and final jurisdiction over election contests, including the power to correct the canvass and declare the rightful winner. The proclamation by the board of canvassers is not final and can be challenged in court.
Conclusion:
The Supreme Court reversed the lower court’s decision and remanded the case for trial on the merits. The amended protest was deemed admissible, and the court emphasized its authority to correct the canvass and declare the rightful winner in election contests.