G.R. No. L-55988 - Digman vs. Commission on Elections

Cecil Digman was the Nacionalista candidate for vice-mayor of La Trinidad, Benguet in the January 30, 1980 local elections.
His opponent, Marcelo U. Aguindadao, was the official candidate of the Kilusang Bagong Lipunan (KBL).
Prior to the election, on January 16, 1980, Aguindadao filed a petition with the Commission on Elections (COMELEC) to disqualify Digman on the ground of turncoatism or political opportunism.

Aguindadao presented evidence that on December 26, 1979, Digman had affiliated himself with the KBL by:

Digman initially sought to run as the KBL candidate for vice-mayor but lost to Cipriano Abalos;
Following his loss in the KBL convention, Digman self-proclaimed as the Nacionalista Party (NP) candidate.

Digman did not submit any evidence to refute these allegations during the proceedings before the COMELEC.

Despite a directive from the COMELEC, issued via telegram on January 31, 1980 instructing the municipal board of canvassers to withhold Digman’s proclamation, the board proceeded to proclaim him on February 5, 1980.
The official vote tally was:

On August 27, 1980, the COMELEC resolved to disqualify Digman from holding the vice-mayor position on the ground of turncoatism, declaring the votes cast in his favor as stray votes.
Subsequently, on December 16, 1980, the COMELEC:

The petition addressed a pre-proclamation controversy regarding the proper remedy for allegations of turncoatism.

The case referenced and relied on established election jurisprudence regarding turncoatism, including previous decisions (e.g., Gabatan, Evasco, Sandalo, Santos, Ticzon, Geronimo).
Notably, the ruling distinguished itself from the case of Venezuela vs. COMELEC concerning post-proclamation disputes and proper remedies (such as election protest or quo warranto proceedings).

Whether the COMELEC’s finding that Digman changed his party affiliation from KBL to NP within six months preceding the election, and consequently committed turncoatism, is supported by sufficient evidence.
Whether, in light of the alleged turncoatism, Digman was disqualified from running under the NP banner and thus should not have been proclaimed as the winning candidate.
Whether the votes cast for Digman, given the factual findings of his party-switch, could legitimately be considered stray votes.
Whether the COMELEC properly exercised its authority in disqualifying Digman post-proclamation and in directing the municipal board of canvassers, notwithstanding its original telegraphic order to withhold the proclamation.
The appropriate remedy for a pre-proclamation controversy on the ground of turncoatism, particularly in relation to election protest and quo warranto proceedings, versus judicial intervention at such an early stage.