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.
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Case Digest (G.R. No. 45869)

Facts:

  1. Background of the Parties:

    • Ciriaco V. Campomanes, the petitioner, was the official candidate of the Sakdalista Party for the position of Provincial Governor of Tayabas in the 1934 general elections.
    • The Sakdalista Party, along with the Nationalist-Democratic Anti Party, presented a complete ticket for all insular, provincial, and municipal positions in Tayabas, including Sariaya, during the 1934 elections.
  2. Current Political Scenario:

    • The Frente Popular, which has absorbed the Sakdalista Party, has candidates for provincial and municipal positions in Sariaya for the upcoming elections.
    • The Nationalist Party and the Frente Popular are the only parties with candidates for provincial positions, while the Nationalist Party and the Reformist Party are the only ones with municipal candidates in Sariaya.
  3. Historical Election Data:

    • In the 1934 elections, the Pula and Puti political groups, both factions of the Nationalist Party in Sariaya, were allied and won against the Reformist and Sakdalista candidates.
    • The Liberal Reformist Party, a purely local group in Sariaya since 1920, has consistently presented a complete ticket for municipal positions but has never fielded candidates for insular or provincial positions or in other municipalities.
  4. Sakdalista Party’s Presence:

    • The Sakdalista Party was established in Tayabas in 1930 but only fielded local candidates in Sariaya during the 1934 elections.
  5. Vote Comparison:

    • In the 1934 elections, the Liberal Reformist Party garnered more votes in Sariaya than the Sakdalista Party.
  6. Proposals for Election Inspectors:

    • On October 4, 1937, the Frente Popular submitted a proposal for election inspectors, signed by its local and provincial representatives.
    • The Liberal Reformist Party and the Nationalist Party also submitted their respective proposals for inspectors on the same date.
  7. Municipal Council’s Decision:

    • The municipal council of Sariaya appointed inspectors for the Nationalist Party and the Liberal Reformist Party but denied the Frente Popular’s request.

Issue:

  1. Primary Issue:

    • Which political organization, the Frente Popular or the Partido Liberal Reformista, is entitled to recognition as an opposition party for the appointment of election inspectors in Sariaya?
  2. Legal Question:

    • Whether a national political party (Frente Popular) or a local political group (Liberal Reformist Party) has a better right to appoint election inspectors under Section 417 of the Election Law, as amended by Commonwealth Act No. 233.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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