Case Digest (G.R. No. 133840)
Facts:
- The case involves Cipriano "Efren" Bautista (petitioner) and the Commission on Elections (COMELEC), along with the Municipal Board of Canvassers of Navotas and Miguelita Del Rosario (respondents).
- The events occurred during the local elections on May 11, 1998, in Navotas, Metro Manila.
- Both the petitioner and Edwin "Efren" Bautista filed their certificates of candidacy for Mayor.
- Edwin Bautista submitted his candidacy just before the deadline on March 27, 1998.
- On April 1, 1998, the petitioner petitioned COMELEC to declare Edwin Bautista a nuisance candidate, which was granted on April 30, 1998.
- On May 10, 1998, conflicting directives were issued regarding Edwin Bautista's name on the candidate list, causing confusion.
- The Regional Election Director instructed the Board of Election Inspectors (BEI) to tally votes for variations of "Efren Bautista" separately.
- The Municipal Board of Canvassers refused to include these stray votes in the valid votes for the petitioner.
- On May 20, 1998, the petitioner filed a petition with COMELEC to declare the canvass proceedings illegal due to the non-inclusion of these votes.
- COMELEC dismissed the petition on May 28, 1998, ruling that stray votes were not part of the official election returns.
Issue:
- (Unlock)
Ruling:
- The Court ruled that the refusal of the Municipal Board of Canvassers to include the Bautista stray votes did not constitute an illegal proceeding.
- The Court found no violation of due process in the issuance of the COMELEC's order.
- The Court concluded tha...(Unlock)
Ratio:
- The Supreme Court held that the Municipal Board of Canvassers acted correctly by not including stray votes, as they were not reflected in the official election returns.
- The Board's duty is to canvass only what is presented in the election returns, and stray votes do not count as valid entries.
- This ruling is supported by Section 211(4) of the Omnibus Election Code, which states that votes with multiple names on the same line are not counted unless one is an incumbent.
- Regarding due process, the Court clarified that the right to be heard can be satisfied through written pleadings, and a formal hearing is not always necessar...continue reading
Case Digest (G.R. No. 133840)
Facts:
The case involves Cipriano "Efren" Bautista (petitioner) and the Commission on Elections (COMELEC), along with the Municipal Board of Canvassers of Navotas and Miguelita Del Rosario (respondents). The events unfolded during the local elections held on May 11, 1998, in Navotas, Metro Manila, where both the petitioner and a certain Edwin "Efren" Bautista filed their certificates of candidacy for the position of Mayor. Edwin Bautista submitted his candidacy at the last minute, just before the deadline on March 27, 1997. On April 1, 1998, the petitioner filed a petition with the COMELEC to declare Edwin Bautista a nuisance candidate, which the COMELEC granted on April 30, 1998, leading to the cancellation of Edwin's candidacy. However, on May 10, 1998, the Election Officer of Navotas issued conflicting directives regarding the inclusion of Edwin Bautista's name in the list of candidates, which created confusion.
To address this, the Regional Election Director instructed the Board of Election Inspectors (BEI) to tally votes for "Efren Bautista," "Efren," "E. Bautista," and "Bautista" separately. Despite this, when the Municipal Board of Canvassers commenced the canvass, they refused to include these stray votes in the valid votes for the petitioner. Consequently, on May 20, 1998, the petitioner filed a petition with the COMELEC to declare the proceedings of the Municipal Board of Canvassers illegal due to the non-inclusion of these votes. The COMELEC dismissed the petition on May 28, 1998, ruling that the stray votes could not be included as ...