G.R. No. 120318 - Canicosa vs. Commission on Elections

The case involves the mayoral race in Calamba, Laguna during the 8 May 1995 elections.
Ricardo “Boy” Canicosa and Severino Lajara were the principal candidates.
Despite Canicosa’s contestation, Severino Lajara secured a majority of approximately 24,000 votes and was proclaimed winner by the Municipal Board of Canvassers.

Canicosa filed a petition with the Commission on Elections (COMELEC) on 15 May 1995 requesting the declaration of failure of election and the nullification of the canvass and proclamation.
The petition alleged widespread election irregularities, which included:

The absence of the names of registered voters from the lists in their respective precincts.
More than one-half of legitimate registered voters being unable to vote, with strangers voting in their stead.
A discrepancy wherein Canicosa was credited with fewer votes than he actually received.
Incomplete filling of the control data in the election returns in certain precincts.
Ballot boxes delivered to the Office of the Municipal Treasurer being unsecured (i.e., lacking padlocks or self-locking metal seals).
Delays in the delivery of election documents and paraphernalia from the precincts.

The petition for failure of election was presented under Section 6 of BP Blg. 881 (the Omnibus Election Code), which limits the declaration of failure of election to:

Instances where voting did not take place on the fixed election date due to force majeure, violence, terrorism, fraud, or analogous causes;
Cases where the election had been suspended before the closing time; or
Situations where, after voting, the preparation, transmission, or custody of election returns resulted in a failure to elect due to the aforesaid causes.

None of the irregularities alleged by Canicosa fell under these specific conditions for declaring a failure of election.
Regulated remedies exist for each of the irregularities mentioned, such as:

Filing a petition for the correction of election returns regarding vote tabulation errors.
Initiating inclusion or exclusion actions concerning the voter list before the regular courts.
Lodge a verified complaint for annulment of the book of voters under the appropriate provisions of RA No. 7166.

Many of the issues raised (voter list discrepancies, vote tally errors, unsecured ballot boxes, and delays in delivery) fall under administrative concerns rather than a ground for failure of election.
COMELEC’s statutory power, under Sec. 52 of BP Blg. 881 and Sec. 2, Art. IX-C of the Constitution, confers broad administrative authority to supervise and regulate the conduct of elections.
Matters involving the integrity of the election process but not constituting a failure of election per se should be remedied through administrative channels established by law.

Whether the allegations of missing registered voter names, substitution of legitimate voters with strangers, and vote tally discrepancies constitute grounds for declaring a failure of election.
Whether the irregularities cited by Canicosa, such as unsecured ballot boxes and delayed delivery of election materials, legally justify the intervention of COMELEC to nullify the election results.
Whether Canicosa availed of the appropriate remedial measures (e.g., filing petitions before the board of election inspectors or approaching the trial courts for inclusion/exclusion issues) in addressing his grievances.
Whether the COMELEC’s decision to rule on the administrative irregularities en banc, instead of first referring the petition to a division followed by a motion for reconsideration, was procedurally proper.