Title
Barroso vs. Ampig, Jr.
Case
G.R. No. 138218
Decision Date
Mar 17, 2000
Election contest over mayoral race; petitioner won but faced multiple Comelec cases. SC upheld trial court, ruling no forum shopping despite incomplete certification, prioritizing public interest over technicalities.
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Case Digest (G.R. No. 138218)

Facts:

Election and Pre-Proclamation Controversies

  • Petitioner Claudius G. Barroso and private respondent Emerico V. Escobillo were candidates for mayor of Tampakan, Cotabato, in the May 11, 1998 elections.
  • Petitioner won the election, but private respondent filed several cases with the Commission on Elections (Comelec) against petitioner, including:
    • SPC 98-009: A pre-proclamation protest under Section 234 of the Omnibus Election Code, alleging vote-buying, bribery, terrorism, and illegal opening of ballot boxes.
    • SPC 98-124: Another pre-proclamation case under Section 241 of the Omnibus Election Code.
    • SPA 98-359: A disqualification case against petitioner for alleged election offenses.
    • Two criminal complaints: Election Offense Case No. 161 (illegal possession of firearm) and Election Offense Case No. 177 (massive vote-buying).

Comelec Resolutions

  • On June 9, 1998, the Comelec First Division dismissed SPC 98-124. Private respondent moved for reconsideration on June 26, 1998.
  • On July 14, 1998, the Comelec First Division dismissed SPC 98-009 without prejudice to filing a proper election protest. Private respondent moved for reconsideration.
  • On July 17, 1998, petitioner was proclaimed as the winning mayoralty candidate by the Municipal Board of Canvassers.

Election Contest

  • On July 27, 1998, private respondent filed an election contest (E. C. Case No. 15-24) with the Regional Trial Court (RTC), Branch 24, Koronadal, South Cotabato.
  • In his petition, private respondent certified that SPA 98-359 and the two criminal cases were pending but failed to disclose the pendency of SPC 98-009 and SPC 98-124.
  • Petitioner filed a motion to dismiss, arguing that private respondent violated the certification against forum shopping under Section 5, Rule 7 of the 1997 Rules of Civil Procedure.

Trial Court Ruling

  • On November 23, 1998, the trial court denied petitioner's motion to dismiss, finding no merit in the claim of forum shopping.
  • On February 24, 1999, the trial court denied private respondent's motion for reconsideration, prompting petitioner to file this petition.

Issue:

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Ruling:

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Ratio:

  1. Non-Applicability of Civil Procedure Rules to Election Cases:

    • Election contests are governed by the Comelec Rules of Procedure, not the Rules of Civil Procedure. The latter apply only by analogy or in a suppletory character.
    • Rule 35 of the Comelec Rules, which governs election contests for municipal officials, does not require a certification against forum shopping.
  2. Liberal Construction of Election Laws:

    • Election laws and rules are to be liberally construed to ensure the will of the electorate prevails over technicalities.
    • The purpose of an election contest is to determine the true choice of the people, which is a matter of public interest.
  3. No Willful Forum Shopping:

    • The trial court found no evidence that private respondent willfully engaged in forum shopping or submitted a false certification.
    • The failure to disclose the pending pre-proclamation cases did not warrant dismissal, especially since SPC 98-124 had already been terminated and SPC 98-009 was dismissed as improper for a pre-proclamation case.
  4. Public Interest Over Technicalities:

    • The revision of ballots had already begun in 10 precincts, and dismissing the case would undermine the public interest in determining the true winner of the election.
    • The Supreme Court emphasized that technical rules of procedure should not defeat the will of the electorate.
  5. Abandonment of Pre-Proclamation Cases:

    • Private respondent’s filing of the election contest effectively abandoned the pre-proclamation cases, as the issues raised in SPC 98-009 were more appropriate for an election protest.

Conclusion:

  • The Supreme Court upheld the trial court's decision, emphasizing the importance of public interest in election cases and the need for a liberal construction of election laws to ensure the true will of the electorate is upheld.


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