Case Digest (G.R. No. 203302) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Mayor Emmanuel L. Maliksi v. Commission on Elections and Homer T. Saquilayan (G.R. No. 203302, March 12, 2013), both Maliksi and Saquilayan ran for Mayor of Imus, Cavite in the May 10, 2010 elections. The Municipal Board of Canvassers proclaimed Saquilayan winner with 48,181 votes to Maliksi’s 39,682. Maliksi thereafter filed Election Protest No. 009-10 before the Regional Trial Court (RTC) of Imus, Cavite, Branch 22. On November 15, 2011, the RTC declared Maliksi duly elected after a revision showing 41,088 valid votes for Maliksi against 40,423 for Saquilayan. Saquilayan appealed to the COMELEC First Division (EAC (AE) No. A-22-2011) and sought certiorari to stop the RTC’s execution pending appeal (SPR (AE) No. 106-2011). The COMELEC First Division, after inspecting ballot boxes and detecting alleged tampering, ordered decryption and printing of the digital images stored in the CF cards and, on August 15, 2012, nullified the RTC’s decision, declaring Saquilayan as the true Case Digest (G.R. No. 203302) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Election and Trial Court Proceedings
- In the 10 May 2010 elections for Imus, Cavite, the Municipal Board of Canvassers proclaimed Homer T. Saquilayan winner with 48,181 votes over Emmanuel L. Maliksi’s 39,682 votes.
- Maliksi filed Election Protest No. 009-10 in RTC Branch 22, contesting 209 clustered precincts. On 15 November 2011, the RTC declared Maliksi duly elected (41,088 vs. 40,423 votes) and granted execution pending appeal.
- COMELEC First Division and En Banc Resolutions
- Saquilayan appealed to COMELEC First Division (EAC (AE) No. A-22-2011). The First Division ordered decryption, printing, and examination of digital ballot images in Compact Flash (CF) cards, applying guidelines on marked, ambiguous, spurious, over-voted, and machine-rejected ballots.
- After recounting digital images, the First Division found Saquilayan obtained 48,521 votes and Maliksi 40,092 votes; on 15 August 2012 it nullified the RTC decision and declared Saquilayan duly elected.
- Maliksi moved for reconsideration and inhibition of Commissioners; on 14 September 2012 the COMELEC En Banc denied reconsideration, affirmed the First Division, and held digital images equivalent to original ballots.
- Maliksi filed a petition for certiorari before the Supreme Court, which issued a temporary restraining order on 11 October 2012 against implementation of the En Banc resolution.
Issues:
- Whether the COMELEC En Banc committed grave abuse of discretion or lacked jurisdiction in its 14 September 2012 Resolution by:
- Depriving Maliksi of due process when the First Division ordered decryption, printing, and examination of digital ballot images without notice.
- Treating ballot images as original evidence instead of mere secondary evidence, to the exclusion of physical ballots.
- Admitting an issue of ballot and ballot-box tampering allegedly belatedly raised.
- Denying Maliksi’s motion for inhibition of Commissioners Sarmiento and Velasco.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)