Case Digest (G.R. No. 146364) Core Legal Reasoning Model
Facts:
The case involves Luis Malaluan (petitioner) and Joseph Evangelista (respondent), contestants for the position of Municipal Mayor of Kidapawan, North Cotabato, in the May 11, 1992 elections. Evangelista was proclaimed the winner by the Municipal Board of Canvassers for garnering 10,498 votes, a margin of 706 over Malaluan’s 9,792 votes. Malaluan filed an election protest with the Regional Trial Court (RTC) on May 22, 1992, contesting 64 of the 181 precincts. The RTC ruled in favor of Malaluan, declaring him the duly elected mayor with a plurality of 154 votes and ordering Evangelista to pay damages including attorney’s fees, expenses, and moral damages. Evangelista appealed to the Commission on Elections (COMELEC), which reversed the RTC decision and declared Evangelista the winner, ordering Malaluan to vacate the office.
Malaluan, after posting a P500,000 bond, was granted execution pending appeal and assumed office. The COMELEC First Division and later the en banc affirmed th
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Case Digest (G.R. No. 146364) Expanded Legal Reasoning Model
Facts:
- Parties and Election Background
- Petitioner Luis Malaluan and private respondent Joseph Evangelista both ran for the position of Municipal Mayor of Kidapawan, North Cotabato in the May 11, 1992 Synchronized National and Local Elections.
- Evangelista was proclaimed winner by the Municipal Board of Canvassers with 10,498 votes against Malaluan's 9,792 votes, giving Evangelista a winning margin of 706 votes.
- Election Protest and Trials
- On May 22, 1992, petitioner Malaluan filed an election protest with the Regional Trial Court (RTC) contesting 64 out of 181 precincts in Kidapawan.
- The RTC declared Malaluan as the duly elected mayor with a plurality of 154 votes and ordered damages, including attorney's fees, moral and exemplary damages.
- Evangelista appealed the RTC decision to the Commission on Elections (COMELEC) on February 3, 1994. A day later, Malaluan filed a motion for execution pending appeal, which the RTC granted upon posting of a P500,000 bond on March 8, 1994. Malaluan assumed office on this basis and exercised mayoral functions.
- COMELEC Ruling and Departmental Proceedings
- The COMELEC First Division reversed the RTC decision, declaring Evangelista as the rightful winner and ordered Malaluan to vacate office.
- The COMELEC en banc affirmed the First Division decision on May 5, 1995.
- Malaluan filed the present petition for certiorari and prohibition on May 31, 1995.
- Mootness of the Case as to Right to Office
- The term of office for the mayor elected in 1992 expired on June 30, 1995, making the issue of right to the office moot and academic.
- However, controversy remains over the propriety of damages awarded by the COMELEC to Evangelista, including attorney's fees, actual expenses, and unearned salary and emoluments from March 1994 to April 1995.
Issues:
- Whether the case, involving an election contest with an expired term of office, has become moot and academic relative to the right of petitioner to hold the contested office.
- Whether the COMELEC gravely abused its discretion in awarding actual damages, including attorney’s fees, actual expenses, and unearned salaries and emoluments to the private respondent Evangelista.
- Whether there exists a legal basis to hold the petitioner liable for actual damages and the award thereof under the applicable laws and jurisprudence.
- Whether the order of execution pending appeal issued by the RTC was lawful and justified.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)