G.R. No. L-32792 - People vs. Bastasa

At the general elections held on June 5, 1934, the candidates for the office of municipal president of Leon, Iloilo, were Jose C. Capalla and Ramon C. Tabiana.
The municipal board of canvassers initially proclaimed Ramon C. Tabiana as the candidate-elect with 836 votes against 809 votes for Jose C. Capalla.

Jose C. Capalla filed a protest challenging the results in certain precincts (specifically precincts 1, 2, and 4).
The Court of First Instance of Iloilo conducted the trial and found that, after excluding invalid votes, Capalla actually received 782 valid votes while Tabiana obtained 756 valid votes, thereby awarding Capalla a majority of 26 votes.
An appeal was made by Ramon C. Tabiana, which led to a review by the Supreme Court in its May 18, 1935 decision (G.R. No. 42986) where the vote counts were slightly readjusted to 786 for Capalla and 760 for Tabiana, still preserving the 26-vote majority in favor of Capalla.

After the May 18 decision, counsel for Ramon C. Tabiana filed a motion for reconsideration based, among other things, on the alleged failure of the lower court to adjudicate 64 ballots from precinct No. 4.
On July 31, 1935, the Supreme Court set aside its previous decision and remanded the case to the trial court for a new trial focusing solely on the unadjudicated ballots from precinct No. 4.
In the remanded trial, additional evidence regarding the contested ballots was presented by both parties, including 20 ballots submitted by Capalla’s counsel and 66 ballots submitted by Tabiana’s counsel.

The trial court’s decision on October 10, 1935, after the new trial in precinct No. 4, resulted in a vote count of 802 for Capalla and 820 for Tabiana, reflecting a new majority of 18 votes in favor of Tabiana.
Following the decision, Capalla, who had previously been declared president-elect, filed an appeal before the Supreme Court—this being the second time the case reached the appellate level.
In his subsequent brief, Capalla raised four assignments of errors challenging the trial court’s proceedings and vote counting.

First Assignment: Alleged that the trial court exceeded its jurisdiction by conducting a new trial after the one-year period provided in section 479 of the Election Law had already expired.
Second Assignment: Challenged the trial court’s admission of 84 ballots in precinct No. 4, asserting that a prior stipulation limited the number of disputed ballots.
Third Assignment: Contended that 64 ballots were improperly counted as valid votes for Tabiana, and alternatively sought annulment of the election in that precinct due to alleged irregularities with ballots prepared for educated voters.
Fourth Assignment: Argued that the trial court erred in not declaring Capalla the municipal president-elect.

Whether conducting a new trial after the expiration of the one-year period prescribed by paragraph 2, section 479 of the Election Law deprived the trial court of its jurisdiction.
The impact of the one-year deadline on proceedings when the Supreme Court’s inherent power to remand is asserted.

Whether the trial court erred in admitting 84 ballots that were not previously adjudicated during the initial trial in precinct No. 4.
The validity of the stipulation made between the parties during the original trial regarding vote counts in precinct No. 4.

Whether the trial court improperly counted 64 ballots as valid for Tabiana in the new trial.
Whether, due to the absence of clear identification of ballots prepared for educated voters by helpers, it was appropriate to reject the ballots or, alternatively, annul the election in precinct No. 4.

Whether the cumulative errors would require the declaration of Capalla as the municipal president-elect despite the new vote count.
The effect of the trial court’s findings on the overall legality and accuracy of the election results.