Case Digest (G.R. No. L-6589)
Facts:
The case titled Eligio Caraecle vs. The Court of Appeals and Felix Del Castillo involves a dispute over the election results for the position of mayor in the municipality of Malangas, Province of Zamboanga, following the general elections held on November 13, 1951. The municipal board of canvassers counted a total of 636 votes for Eligio Caraecle and 612 for Felix del Castillo, leading to Caraecle's proclamation as mayor. Del Castillo, the rival candidate, contested the result by filing a protest against the election of Caraecle, specifically contesting 39 ballots that were counted in favor of Caraecle. Caraecle responded to this protest by contesting 37 ballots that had been counted for Del Castillo.The dispute resulted in a hearing at the Court of First Instance of Zamboanga, which ruled that 28 out of the contested ballots favored Del Castillo, while 16 favored Caraecle. The court ultimately added the 28 valid votes to Del Castillo's uncontested total of 601, resulting
Case Digest (G.R. No. L-6589)
Facts:
- Background of the Election
- The municipal board of canvassers tallied votes in the mayoral election in Malangas, Province of Zamboanga, held on 13 November 1951.
- Eligio Caraecle obtained 636 votes.
- Felix del Castillo obtained 612 votes.
- Both candidates subsequently initiated electoral protests.
- Felix del Castillo (protestant) filed a protest contesting 39 ballots counted in favor of Caraecle.
- Eligio Caraecle (protestee) filed a counter protest contesting 37 ballots counted in favor of Castillo.
- Proceedings and Vote Adjustment
- Trial Court Determination
- The Court of First Instance of Zamboanga examined the contested ballots.
- It declared 28 out of 37 contested ballots valid in favor of Castillo and 16 out of 39 valid in favor of Caraecle.
- Computation of the Final Vote Count
- Uncontested votes were recorded as 601 for Castillo and 596 for Caraecle.
- Adding the admitted contested votes resulted in:
- 601 + 28 = 629 votes for Castillo.
- 596 + 16 = 612 votes for Caraecle.
- This produced a plurality in favor of Felix del Castillo.
- Appeal and Review
- Both parties appealed the trial court’s judgment.
- The Court of Appeals affirmed the decision, modifying only the numerical plurality determinations.
- The case eventually reached the Supreme Court for final review.
- Contested Ballot Issues
- Ballot B-15 (Precinct No. 1)
- The ballot carried the inscription “Cebarle” on the space for mayor.
- The controversy centered on whether “Cebarle” was phonetically equivalent to “Caraecle.”
- An additional note on the ballot (“Mayor Castillo” on a space designated for Senators) complicated the interpretation.
- Ballot B-16 (Precinct No. 1)
- The ballot did not have a mark in the prescribed space for mayor.
- Instead, it bore the words “Mayor” on the third space for councilors and “F. del Castillo” on the fourth space.
- The inconsistency raised the issue whether the voter’s intention for Castillo should be inferred.
- Ballot A-2 (Precinct No. 1-A)
- Although it contained marks indicating votes for various candidates, the name of Caraecle was written in Arabic while others were in Roman characters.
- This disparity led to questioning the ballot’s validity.
- Ballot A-4 (Precinct No. 7)
- The ballot had the capital letters “MBDC” written on the third space for Senators.
- The inscription was seen as an impertinent identification mark rather than a directive vote.
- Other Marked Ballots
- Several other ballots (identified as A-1, A-2, A-1, A-6, A-1, A-2, and A-3 from various precincts) contained impertinent or extraneous notations.
- The trial court rejected these as marked ballots on the ground that such writings vitiated the ballot.
- Final Outcome and Cost Implications
- After all adjustments and reassignments (including the allocation of ballot B-15 and the rejection of certain marked ballots), the final vote count favored Felix del Castillo by a plurality of 16 votes.
- The decision similarly included the imposition of costs against the protestee, Eligio Caraecle.
- Concurrence was expressed by several justices, affirming the multi-level judicial findings.
Issues:
- Validity of Contesting Specific Ballots
- Whether ballot B-15, which bore the inscription “Cebarle,” should be counted in favor of Caraecle.
- Consideration of phonetic equivalence to “Caraecle.”
- Analysis of the additional inscription “Mayor Castillo” written in a space not designated for the mayor.
- Whether the contested ballots (B-16, A-2, and A-4) should be deemed valid votes for the respective candidates.
- On ballot B-16, if the marks on non-designated spaces conclusively indicate the voter's intent for Castillo.
- On ballot A-2, whether the mixing of Arabic and Roman characters affects the integrity of the vote.
- On ballot A-4, whether the impertinent inscription “MBDC” invalidates the ballot.
- Interpretation of the Voter’s Intent
- How strictly the courts must adhere to the designated spaces on the ballot.
- The extent to which extraneous or impertinent writings on the ballot may override the apparent voter’s intention.
- Costs and Discretion of the Courts
- Whether the taxing of costs against the protestee was proper under the provisions of section 180 of the Revised Election Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)