Title
Arrieta vs. Rodriguez
Case
G.R. No. 37524
Decision Date
Dec 12, 1932
1931 Palawan election tie; Arrieta protested Coron results, Rodriguez counter-protested late. SC ruled counter-protest untimely, upheld Coron validity, declared Arrieta winner by 54 votes.
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Case Digest (G.R. No. 37524)

Facts:

Election Context:

  • The case involves an election protest filed by Miguel Arrieta (protestant and appellant) against Mariano Rodriguez (protestee and appellee), both of whom were official candidates for the office of member of the provincial board of Palawan in the elections held on June 2, 1931.
  • The election for the office was declared a tie by the provincial board of canvassers, with both candidates receiving 2,054 votes.
  • The Philippine Senate, acting under Section 475 of the Election Law, resolved on August 20, 1931, to proclaim Mariano Rodriguez as the elected member of the provincial board of Palawan.

Protest and Counter-Protest:

  • On September 2, 1931, Miguel Arrieta filed a motion of protest in the Court of First Instance of Palawan, seeking the annulment of the election in eight precincts of the municipality of Coron.
  • Mariano Rodriguez was summoned on September 8, 1931, and filed his answer and counter-protest on October 2, 1931. The counter-protest contested the election results in several precincts of other municipalities.
  • Arrieta moved to dismiss the counter-protest, arguing it was filed outside the statutory period, but the court denied the motion.

Evidence and Trial:

  • Both parties agreed to use the same exhibits and testimony from a related case (G.R. No. 37523, Patricio Fernandez vs. Higinio Mendoza) since the allegations and evidence were identical.
  • The trial court upheld the validity of the election in Coron, awarding Rodriguez 638 votes and Arrieta 137 votes in that municipality.
  • After considering the counter-protest, the court declared Rodriguez the winner with 2,076 votes against Arrieta’s 2,010 votes, a plurality of 60 votes.

Appeal:

  • Arrieta appealed the decision, assigning twelve errors, including the court’s lack of jurisdiction to hear the counter-protest.

Issue:

  1. Whether the counter-protest filed by Mariano Rodriguez was filed within the statutory period prescribed by Section 481 of the Election Law.
  2. Whether the trial court had jurisdiction to hear and decide the counter-protest.
  3. Whether the election results in the contested precincts of Coron were valid.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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