Title
Campomanes vs. Municipal Council of Sariaya, Tayabas
Case
G.R. No. 45869
Decision Date
Dec 8, 1937
A national political party (Frente Popular) prevails over a local group (Liberal Reformist Party) for appointing election inspectors in Sariaya under election law.

Case Digest (G.R. No. 45869)

Facts:

  • Background of the Case
    • The petitioner, Ciriaco V. Campomanes, filed an original action for a writ of mandamus.
    • The petition sought to compel the Municipal Council of Sariaya, Tayabas, to appoint one inspector and one substitute inspector of election for each precinct, in favor of the Frente Popular.
  • Political Party and Group Affiliations
    • Ciriaco V. Campomanes was affiliated with the Partido Sakdalista and had been its official candidate for Governor in the 1934 elections.
    • In the 1934 elections, multiple tickets were presented in Tayabas by various parties:
      • The Partido Sakdalista and the Partido Nacionalista – Democratico Anti presented complete tickets for insular, provincial, and municipal positions.
      • The Frente Popular, emerging later, fielded candidates for provincial and municipal offices.
      • The Partido Liberal Reformista, a purely local group in Sariaya active since 1920, consistently presented a complete ticket for municipal positions but did not contest for insular or provincial offices in other municipalities.
  • Conflict Over Inspector Appointments
    • The municipal council of Sariaya initially appointed inspectors (as evidenced by Exhibit C) for a local political organization known as the Pula-Puti group, which was identified as a branch of the Partido Nacionalista.
    • The dispute centers on two competing claims:
      • The Partido Liberal Reformista, which had already been given an inspector and a substitute inspector by the municipal council.
      • The Frente Popular, which argued that, as a bona fide political party, it was entitled to such appointments instead.
  • Stipulated Facts and Exhibit Evidence
    • A mutual stipulation of facts submitted by the parties detailed the history and affiliations of the political organizations involved, including:
      • The consistent local activity of the Partido Liberal Reformista in Sariaya.
      • The formation and electoral participation of the Partido Sakdalista only in 1934 in Sariaya.
      • Electoral performance data (the vote counts of the various tickets) provided in the exhibits.
    • Proposals for the appointment of inspectors were submitted by authorized representatives of the Frente Popular, Partido Liberal Reformista, and Partido Nacionalista on various dates (October 2 and October 4, 1937).
  • Legal Framework and Admission of Evidence
    • The parties agreed to admit affidavits regarding whether any confabulacion existed between the Frente Popular and the Partido Liberal Reformista.
    • There was no dispute over the right of the Partido Nacionalista to its inspectors, nor on the fact that the appointments for that party were made in conformity with the proposals of their duly authorized representatives.

Issues:

  • Determination of Entitlement to Inspector Appointments
    • Which political organization, between the Frente Popular and the Partido Liberal Reformista, is entitled to have an inspector and a substitute inspector of election appointed in each precinct of Sariaya?
  • Classification of the Political Organizations
    • Whether the Frente Popular qualifies as a political party under the statutory definition (specifically within the meaning of paragraph (h) of Section 417 of the Election Law).
    • Whether the Partido Liberal Reformista, being a local political group, is entitled to the same rights as a national political party in the context of inspector appointments.
  • Interpretation of Statutory Provisions
    • The proper application of Section 417 of the Election Law, as amended by Commonwealth Act No. 233, particularly paragraphs (c) and (f).
    • Whether the intent of the legislature to promote national political parties for election purposes supports the Frente Popular’s claim over the local group.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.