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 vo...

Facts:

1. Election Context:

   • In the 1980 local elections in Morong, Bataan, three candidates ran for Municipal Mayor: Antonio S. Calimbas (KBL), Armando M. Quimlat (NP), and Benjamin Escolango (NUL).
   • On January 31, 1980, Calimbas was proclaimed the winner with 2,545 votes, while Quimlat received 2,103 votes, resulting in a plurality of 442 votes.

2. Election Protest:

   • On February 7, 1980, Quimlat filed an election protest with the Court of First Instance of Bataan, alleging fraud, vote-buying, and terrorism in Voting Centers 1 and 2 of Mabayo, Morong, Bataan.
   • Quimlat specifically claimed that in Voting Center No. 1, only 299 voters cast their votes, but 644 votes were counted.

3. Trial Court Decision:

   • On March 17, 1982, the trial court dismissed Quimlat's protest, finding no factual basis for the allegations of fraud. It declared Calimbas the duly elected Mayor with a plurality of 113 votes.

4. COMELEC Appeal:

   • Quimlat appealed to the Commission on Elections (COMELEC).
   • On January 15, 1985, the COMELEC reversed the trial court's decision, nullifying all votes cast in Voting Center No. 1 due to 151 excess votes. It declared Quimlat the winner with 1,762 votes against Calimbas's 1,719 votes.

5. Supreme Court Intervention:

   • Calimbas filed a Petition for Certiorari with the Supreme Court, challenging the COMELEC's decision.
   • The Supreme Court issued a Temporary Restraining Order, preventing Quimlat from assuming office.

6. Key Issue Before the Supreme Court:

   • The sole issue was whether the COMELEC abused its discretion in concluding that there were 151 excess votes in Voting Center No. 1.

7. Evidence and Findings:

   • The Supreme Court found inconsistencies and inaccuracies in the COMELEC's data, particularly in equating "registered voters" with "actual voters."
   • The COMELEC's computation of excess votes was based on erroneous assumptions, as it failed to account for the actual number of registered voters (491) and the number of ballots cast (380).

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Excess Votes Determination:

   • The COMELEC's computation of excess votes was flawed because it erroneously equated "registered voters" with "actual voters." The Court emphasized that not all registered voters cast their votes on election day.
   • The correct method for determining excess votes involves comparing the number of registered voters, the number of voters who actually cast their votes, and the number of ballots found in the ballot box.

2. Inaccuracies in COMELEC's Data:

   • The COMELEC relied on inconsistent and inaccurate data, including discrepancies in the "Minutes of Voting & Counting of Votes" and the List of Registered Voters.
   • The Supreme Court found that the actual number of registered voters in Voting Center No. 1 was 491, and the number of ballots cast was 380, negating any claim of excess voting.

3. Primacy of the True Will of the Electorate:

   • The Court reiterated that the power to nullify an election should be exercised with great caution and only in extreme cases of fraud or fundamental disregard of the law. No such circumstances were present in this case.

4. Official Documents and Evidence:

   • The List of Registered Voters submitted by the COMELEC was deemed an official document, and its reliability was upheld despite Quimlat's claim that it was spurious.

Conclusion:

The Supreme Court ruled in favor of Calimbas, reinstating his victory as the duly elected Municipal Mayor of Morong, Bataan. The COMELEC's decision was set aside due to its grave abuse of discretion and reliance on erroneous data.