Facts:

The case of Manuel Aquino et al. vs. Judge of First Instance of Cagayan et al. arose from a municipal election held on June 6, 1916, in the municipality of Amulung, Province of Cagayan. The election was conducted to select a president, a vice-president, and councilmen for the municipality. Following the election, a canvass of the votes was performed, resulting in the declaration of certain candidates as elected officials by the municipal board of inspectors. On June 19, 1916, a joint protest against the election results was filed by several candidates who had run for the positions of president, vice-president, and councilmen. Notice of this protest was duly given to all opposing candidates, except for two candidates who were vying for the councilman positions. Subsequently, a motion was filed to dismiss the protest on the grounds that the court lacked jurisdiction to hear it, as the two councilman candidates had not been notified. The lower court considered this motion ...

Facts:

Election and Canvass Details

• An election was held in the municipality of Amulung, Province of Cagayan on June 6, 1916.
• The election was conducted to elect a president, a vice-president, and councilmen for the municipality.
• At the close of the election, a canvass of the votes was performed.
• Based on the canvass, certain candidates were declared elected as officers by the municipal board of inspectors.

Filing of the Protest

• On June 19, 1916, a joint protest was presented by some of the candidates contesting the election.
• The protest was filed against the election results as determined by the municipal board.
• Notice of the protest was disseminated to all opposing candidates who had been voted for in the respective offices, except for two candidates for the office of councilman.

Dismissal of the Protest and Subsequent Petition

• A motion was made to dismiss the protest on the ground that the court did not have jurisdiction due to the failure to give notice to two candidates for councilman.
• The court, based on the motion and the lack of complete notice, dismissed the protest.
• The present petition was subsequently filed to compel the lower court (the Court of First Instance of the Province of Cagayan) to:
• Reinstate the protest.
• Hear and determine the protest on its merits.

Respondents’ Arguments and Objections

• The respondents argued that the lower court was without jurisdiction to hear the protest until all candidates voted for at the election were duly notified of the protest.
• They further contended that the protest should have been dismissed on the ground of improper joinder of parties:
• Candidates for president, vice-president, and councilmen were incorrectly joined in one protest.
• Separate protests should have been presented by the candidates for each respective office.

Court’s Observations on the Notice Issue

• The court noted that:
• The failure to notify the two councilman candidates should not affect the protest as it pertained to the offices of president and vice-president.
• Dismissing the protest for these offices would be a violation of the rights of the corresponding candidates.
• With regard to the candidates for councilman, the court emphasized that:
• Whether or not they had been duly notified was a factual matter.
• Proof should have been heard by the lower court to determine if proper notice was given in compliance with the law.

Issue:

• Whether the failure to give notice to the candidates for the office of councilman should bar the protest for the offices of president and vice-president.
• Whether the dismissal of the protest without hearing evidence regarding the alleged lack of notice to some candidates was proper.
• Whether the joinder of candidates for different offices (president, vice-president, and councilmen) in one protest was appropriate or if separate protests should have been required.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)