A.C. No. 6297 - Parinas vs. Paguinto

In the 1922 general elections for the office of Governor of Rizal, three candidates contested:

With a plurality of 360 votes, Rodriguez was proclaimed elected.
Following the proclamation, Angeles, the defeated candidate, filed a protest alleging numerous errors, frauds, and irregularities during the election.

The election protest was initiated by Angeles and involved a counter-protest from Rodriguez.
A trial was conducted before Judge of First Instance Llorente, who dismissed the protest with costs and incidental expenses against Angeles.
A preliminary issue arose regarding the status of the contestee (Rodriguez), who had resigned from office but continued to actively oppose the protest, raising the question of whether his resignation removed him as an adversary in the contest.

Irregularities in precincts of Cardona, Makati, and Malabon (Errors I-IV)
Irregularities in precincts of Montalban (Errors V-VIII)
Additional miscellaneous errors including bribery, and the admission/exclusion of ballots in various municipalities (Errors IX-XIII, and Error XV)

The appellant contended that the errors ranged from technical missteps to acts amounting to fraud, which he argued should have invalidated certain votes thereby changing the overall result.

Allegation that detachable numbers on ballots were not removed before deposition in the ballot box, in violation of section 442 (as amended) of the Election Law.
The failure to detach was argued to be a mechanism of fraud devised to eventually verify the voter’s choice using pre-arranged lists.
Contention: Had the affected ballots (709 for Rodriguez and 327 for Angeles) been eliminated, Angeles would have won by a small plurality.

Extremely lopsided returns in precincts Nos. 1 and 2 were noted, with Rodriguez receiving 388 votes to Angeles’ 12 in these areas—a difference of 376 votes.
Several procedural and administrative irregularities were alleged:

Appointment and composition of the election board favoring one party.
Violation of statutory provisions regarding the appointment of a chairman (section 421) and the omission of procedures such as voter oaths.
The use of improper ballot series (e.g., ballots of series “E” instead of “A”) and problems concerning the disappearance of detachable slips or copies of oaths.
Inconsistencies in the handling, admission, or exclusion of ballots, including allegations that ballots without detachable numbers were nevertheless counted.

Bribery allegations in the barrio of Darangan (Binangonan) and Lamayan (San Felipe Neri), where actions such as giving a check for repairs and furnishing construction materials were construed as attempts to sway voters.
Disputes over the admission and exclusion of certain ballots based on varied exhibits, with the conclusion that even a correct tally of these would not alter the overall result.
Throughout, the evidence was predominantly oral, the documentary proof was lacking in critical areas, and many assertions were found to be insufficiently substantiated.

Whether the resignation of Rodriguez from the office of governor automatically removed him as a party to the election contest, given his continued active opposition and party interest in the outcome.

Whether the failure to remove the detachable numbers on ballots (a requirement under section 442 of the Election Law) was a mandatory rule that, if violated, should invalidate the votes cast.
Whether the alleged errors and irregularities committed in various precincts could be considered as deliberate acts of fraud sufficient to overturn the election result.

Whether the numerous administrative errors (improper appointment of election officials, missing documents, use of different ballot series, etc.) materially affected the integrity of the election process and the expression of the voters’ will.
The relevance of oral testimony and the absence of corroborative documentary evidence in substantiating claims of fraud or irregularities.

Whether, in aggregate, the alleged irregularities—if remedied—would have altered the result of the election, particularly the narrow vote margins in disputed areas.