Case Digest (G.R. No. L-69932)
Facts:
- Antonio S. Calimbas is the petitioner against the Hon. Commission on Elections (COMELEC) and Armando M. Quimlat.
- The case arose from the local elections on January 30, 1980, in Morong, Bataan, where three candidates vied for the Municipal Mayor position: Calimbas (KBL), Quimlat (NP), and Benjamin Escolango (NUL).
- On January 31, 1980, the Municipal Board of Canvassers proclaimed Calimbas as the elected mayor with 2,545 votes, surpassing Quimlat's 2,103 votes by 442 votes.
- Quimlat filed an election protest on February 7, 1980, alleging fraud and discrepancies in Voting Center No. 1, claiming 299 voters cast votes while 644 were counted.
- Calimbas denied the allegations and filed a counter-protest regarding other voting centers.
- On March 17, 1982, the trial court ruled in favor of Calimbas, confirming his election with a plurality of 113 votes over Quimlat.
- Quimlat appealed to the COMELEC, which reversed the trial court's decision on January 15, 1985, declaring Quimlat the winner with 1,762 votes against Calimbas's 1,719 votes.
- Calimbas's motion for reconsideration was denied, leading him to file a petition for certiorari on February 18, 1985.
- The Supreme Court issued a Temporary Restraining Order on February 21, 1985, preventing Quimlat from assuming office.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled in favor of Antonio S. Calimbas.
- The Court set aside the COMELEC's decision dated January 15, 1985, and reinstated the trial court's ruling declaring Calimbas as the duly elected Municipal Mayor of...(Unlock)
Ratio:
- The Supreme Court determined that the COMELEC gravely abused its discretion in declaring excess votes in Voting Center No. 1.
- The Court emphasized that the assessment of excess votes must rely on accurate data regarding registered voters, actual voters, and the number of ballots in the ballot box.
- The COMELEC's assumption that "registered voters" equated to "actual voters" wa...continue reading
Case Digest (G.R. No. L-69932)
Facts:
The case involves Antonio S. Calimbas as the petitioner and the Hon. Commission on Elections (COMELEC) and Armando M. Quimlat as the respondents. The events leading to this case began with the local elections held on January 30, 1980, in Morong, Bataan, where three candidates contested for the position of Municipal Mayor: Antonio S. Calimbas (KBL), Armando M. Quimlat (NP), and Benjamin Escolango (NUL). Following the elections, on January 31, 1980, the Municipal Board of Canvassers proclaimed Calimbas as the duly elected Municipal Mayor, having received 2,545 votes compared to Quimlat's 2,103 votes, resulting in a plurality of 442 votes.
On February 7, 1980, Quimlat filed an election protest against Calimbas in the then Court of First Instance of Bataan (Election Case No. 314), alleging fraud, massive vote-buying, and terrorism, particularly citing discrepancies in Voting Center No. 1 in Barangay Mabayo, where he claimed that only 299 voters cast their votes, yet 644 votes were counted. Calimbas denied these allegations and filed a counter-protest contesting results in other voting centers.
On March 17, 1982, the trial court ruled in favor of Calimbas, declaring him the duly elected mayor with a plurality of 113 votes over Quimlat. Quimlat subsequently appealed to the COMELEC, which on January 15, 1985, reversed the trial court's decision. The COMELEC found that there were 151 ex...