Case Digest (G.R. No. L-17587)
Facts:
Congressman Alan Peter S. Cayetano, with Taguig-Pateros, filed two petitions for certiorari against the Commission on Elections (COMELEC), Ma. Salvacion Buac, and Antonio Bautista, assailing the COMELEC en banc’s resolutions on the April 25, 1998 plebiscite in Taguig, Metro Manila for the conversion of the municipality into a highly urbanized city under Republic Act No. 8487. The plebiscite canvass was initially declared to favor “No,” but the COMELEC ordered the Plebiscite Board of Canvassers to reconvene and complete the canvass, after which negative votes still prevailed; respondents then sought annulment of the announced results, alleging fraud and irregularities, and the COMELEC treated the case as an election protest and proceeded with revision and recount.
After a prior Supreme Court ruling reinstated the petition and directed its prompt resolution, the COMELEC Second Division conducted revision proceedings; because the required votes were not obtained, the case was elevated to the COMELEC en banc, which on December 8, 2004 declared and confirmed the ratification and approval of the conversion, and on January 28, 2005 declared the resolution final and executory and recorded it in the Book of Entry of Judgments. Cayetano then challenged the December 8, 2004 resolution and the January 28, 2005 finality/entry.
Issues:
- Whether the COMELEC committed grave abuse of discretion in declaring the conversion of Taguig into a highly urbanized city based on the revision/recount of plebiscite ballots.
- Whether the Supreme Court could review the alleged incomplete canvass and claimed irregularities, frauds, and anomalies raised against the COMELEC’s factual findings in a Rule 65 petition.
Ruling:
The Court dismissed both petitions for lack of merit. It held that the issues raised were largely factual—on the admissibility and sufficiency of evidence during the revision proceedings—and thus were not reviewable in Rule 65, except for limited jurisdictional grave abuse of discretion.
The Court nonetheless examined the records and found no grave abuse of discretion, ruling that the COMELEC considered not only the PBOC canvassing report totals but also the results from the physical count, the uncontested precincts, and the appreciation of contested ballots, and that these supported findings deserved finality and the presumption of regularity.
Ratio:
The Court ruled that questions concerning an alleged incomplete canvass and alleged irregularities during the revision and recount pertain to factual matters requiring evaluation of evidence and ballot appreciation, which are within the COMELEC’s exclusive competence. Under Rule 65, the Court’s review is confined to issues involving jurisdiction, including grave abuse of discretion amounting to lack or excess of jurisdiction, and the COMELEC’s determinations on election plebiscite results are entitled to finality absent clear showing of jurisdictional error.
Applying this, the Court accepted the COMELEC’s consolidated computation of affirmative and negative votes based on multiple components of the canvass and recount process, and found that the challenged resolutions were issued without grave abuse of discretion. It emphasized that the COMELEC’s expertise and constitutional mandate make its acts presumptively regular, and matters involving plebiscite result determination are best left to the COMELEC.
Doctrine:
- Under Rule 65, the Supreme Court generally does not resolve factual issues or reweigh evidence on election or plebiscite matters, limiting review to jurisdictional errors, including grave abuse of discretion amounting to lack or excess of jurisdiction.
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