Case Digest (G.R. No. 162037)
Facts:
In early 1988, Datu Jamil Dimaporo was proclaimed Mayor-elect of Marogong, Lanao del Sur, by the Municipal Board of Canvassers on February 3, 1988. Defeated candidates Datu Abdulmadid Panondiongan Maruhom (SPC No. 88-646) and Monabai Panondiongan Balt (SPC Nos. 88-697, 88-697-A) filed petitions before the Commission on Elections (COMELEC) First Division to annul the proclamation. While these petitions were pending, the Secretary of Local Governments designated Maclis Balt as Officer-in-Charge Mayor on May 19, 1988, a designation later recognized by Governor Saidamen Pangarungan on May 23, 1988. On July 11, 1988 the COMELEC First Division dismissed the petitions and affirmed Dimaporo’s proclamation, prompting both Maruhom and Balt to file motions for reconsideration. On July 18, 1988, Dimaporo’s counsel formally requested Governor Pangarungan to accord recognition to Dimaporo as mayor. Acting Governor Saaddudin Alauya then referred the matter by 3rd indorsement (August 1, 1988) t...Case Digest (G.R. No. 162037)
Facts:
- Election controversy in Marogong, Lanao del Sur
- On February 3, 1988, the Board of Canvassers proclaimed Datu Jamil Dimaporo as Mayor-elect of Marogong.
- Two defeated candidates, Datu Abdulmadid Panondiongan Maruhom and Monabai Panondiongan Balt, filed separate petitions before the COMELEC First Division seeking annulment of the proclamation.
- Appointment of Officer-in-Charge and provincial directives
- While the petitions were pending, the Secretary of Local Governments (May 19, 1988) designated Maclis Balt as OIC-Mayor of Marogong, and Governor Saidamen Pangarungan lifted financial suspensions on municipal accounts.
- Maclis Balt assumed mayoral functions pending final resolution of the COMELEC proceedings.
- COMELEC First Division decision and subsequent correspondence
- On July 11, 1988, the COMELEC First Division dismissed the petitions, affirmed Dimaporo’s proclamation, and denied reconsideration en banc on October 28, 1988.
- Dimaporo’s counsel requested provincial recognition (July 18, 1988); Vice-Governor Alauya forwarded the request to Provincial Fiscal Dumarpa for opinion.
- On August 5, 1988, 3rd Assistant Provincial Fiscal Danganan, with Fiscal Dumarpa’s conformity, opined in writing that Balt remained OIC-Mayor because the First Division decision was not yet final and executory due to pending motions for reconsideration.
- Motion for contempt before COMELEC en banc
- On August 22, 1988, Dimaporo filed a motion to hold Alauya, Dumarpa, and Danganan in indirect contempt for “improper conduct” allegedly obstructing COMELEC proceedings and causing public confusion.
- The COMELEC en banc, by Resolution dated October 28, 1988, found respondents guilty of contempt, fined each P500, and denied their motion for reconsideration on January 12, 1989.
- Respondents then filed a special civil action of certiorari with the Supreme Court to annul the contempt ruling.
Issues:
- Did the issuance and communication of the legal opinion by the provincial fiscals and Vice-Governor constitute contempt of the COMELEC en banc by unlawfully interfering with its exclusive jurisdiction over pre-proclamation controversies?
- Was the COMELEC en banc’s contempt finding supported by factual and legal grounds, or was it an abuse of discretion?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)