Title
Supreme Court
Legaspi et al. vs. Commission on Elections
Case
G.R. No. 264661
Decision Date
Jul 30, 2024
Petitioners requested a manual recount of votes for alleged election anomalies but the Supreme Court dismissed it for lack of jurisdiction and valid basis.

Case Digest (G.R. No. 264661)
Expanded Legal Reasoning Model

Facts:

  • Petitioners and the APELA Document
    • Petitioners Clarylyn A. Legaspi et al. filed a class suit representing voters in Pangasinan claiming denial of their rights to suffrage, petition for redress, and information on public matters due to COMELEC’s inaction on their request for a manual recount.
    • On May 27, 2022, COMELEC received "APELA PARA SA MANO-MANONG PAGBILANG MULI NG MGA BOTO SA PROBINSYA NG PANGASINAN" (APELA), a signature campaign demanding a manual recount due to alleged widespread cheating in the May 9, 2022 elections.
    • The APELA first page stated the voters' belief that election results violated their rights and requested a manual recount for truth and rightful proclamation.
    • Albert O. Quintinita submitted the APELA; petitioners claim Atty. Laudemer I. Fabia prepared and circulated it.
    • Signature pages of the APELA were not included in the record.
  • COMELEC's Response to APELA
    • COMELEC’s Law Department responded on May 31, 2022, stating the APELA lacked specific electoral contest details and instructed that election protests must be filed by losing candidates contesting specific positions through proper channels (COMELEC or Regional Trial Court).
    • Petitioners sought reconsideration on June 15, 2022, emphasizing APELA as a people's initiative, not an electoral protest, invoking their constitutional right to information and suffrage.
    • Petitioners expressed willingness to shoulder recount expenses and requested the audit to be witnessed publicly, allowing independent IT audits of SD cards and manual counting with the tambiolo system.
    • COMELEC reiterated it had no jurisdiction over the petition as a people's initiative, provided guidelines on proper filing, and emphasized administrative procedures.
  • Petitioners' Arguments
    • Petitioners contend the case is not an electoral protest but an election controversy regarding their fundamental rights.
    • They claim COMELEC confused their request with electoral protests or initiatives and failed to see these were not mutually exclusive remedies.
    • Petitioners alleged no compelling interest by COMELEC to deny recount, thus violating rights.
    • They represent over 71,000 Pangasinan voters demanding recount due to statistical improbabilities and irregularities including unusually high voter turnout and rapid result transmission.
    • They highlighted independent experts' opinions questioning vote counting transparency.
  • COMELEC's Opposition
    • COMELEC argued defective verification based on lack of personal knowledge and reliance on hearsay from social media.
    • It argued lack of locus standi as petitioners had no personal injury, and insufficient representation of the voting class.
    • COMELEC also claimed no case or controversy exists as petitioners do not seek to nullify elections or unseat officials.
  • Judicial Affidavits and Additional Points
    • Petitioners' affidavits express doubt about election outcome transparency and attest to their understanding of the petition.
    • Petitioners cite prior related cases supporting COMELEC's authority to conduct manual recounts when VCMs malfunction or corrections are needed.

Issues:

  • Whether the verification of the petition is defective due to lack of personal knowledge.
  • Whether petitioners have locus standi to bring the action.
  • Whether the petition qualifies as a class suit.
  • Whether an actual case or controversy exists.
  • Whether petitioners exhausted all administrative remedies before resorting to the Court.
  • Whether certiorari or mandamus is the proper remedy.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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