Case Digest (G.R. No. 203302)
Facts:
- Emmanuel L. Maliksi filed an election protest against the Commission on Elections (COMELEC) and Homer T. Saquilayan after the latter was proclaimed Mayor of Imus, Cavite, in the 2010 elections.
- Maliksi, who received the second-highest votes, alleged irregularities in the counting of votes from 209 clustered precincts.
- The Regional Trial Court (RTC) revised the votes and declared Maliksi as the duly elected Mayor, ordering Saquilayan to stop performing his duties.
- Saquilayan appealed to the COMELEC, while the RTC allowed Maliksi to assume the position pending appeal.
- The COMELEC First Division conducted a recount using printouts of ballot images without notifying the parties involved and required Saquilayan to deposit funds for decryption and printing.
- On August 15, 2012, the COMELEC nullified the RTC's decision, declaring Saquilayan as the duly elected Mayor.
- Maliksi claimed he was denied due process due to lack of notice and the use of secondary evidence without proof of the original ballots' integrity.
- The COMELEC En Banc denied Maliksi's motion for reconsideration, leading him to file a petition for certiorari with the Supreme Court.
- The Supreme Court dismissed his petition on March 12, 2013, stating he was not denied due process.
- Maliksi later filed an Extremely Urgent Motion for Reconsideration, raising further arguments regarding due process violations.
Issue:
- (Unlock)
Ruling:
- The Supreme Court granted Maliksi's Extremely Urgent Motion for Reconsideration, reversing the March 12, 2013 decision, citing due process violations by the COMELEC.
- The Court annulled the recount proceedings conducted by the COMELEC First Division using printouts of ballot images.
- The Court did not addr...(Unlock)
Ratio:
- The Supreme Court emphasized that due process mandates that parties receive notice and an opportunity to be heard in adversarial proceedings.
- Maliksi was not adequately informed about the decryption and printing of ballot images, constituting a signific...continue reading
Case Digest (G.R. No. 203302)
Facts:
The case involves Emmanuel L. Maliksi as the petitioner and the Commission on Elections (COMELEC) and Homer T. Saquilayan as the respondents. The events unfolded during the 2010 elections in Imus, Cavite, where Saquilayan was proclaimed the winner for the position of Mayor by the Municipal Board of Canvassers. Maliksi, who received the second-highest number of votes, filed an election protest in the Regional Trial Court (RTC) of Imus, alleging irregularities in the counting of votes across 209 clustered precincts. The RTC conducted a revision of the votes and subsequently declared Maliksi as the duly elected Mayor, ordering Saquilayan to cease performing the functions of the office. Saquilayan appealed this decision to the COMELEC. Meanwhile, the RTC granted Maliksi's motion for execution pending appeal, allowing him to assume the position of Mayor.
In the appeal, the COMELEC First Division, without notifying the parties, decided to recount the ballots using printouts of ballot images from the CF cards. It issued orders requiring Saquilayan to deposit funds for the decryption and printing of these images. On August 15, 2012, the First Division nullified the RTC's decision and declared Saquilayan as the duly elected Mayor. Maliksi filed a motion for reconsideration, claiming he was denied due process due to a lack of notice regarding the decryption proceedings and the use of secondary evidence (the printouts) without proof of the integrity of the original ballots. The COMELEC En Banc denied his motion on September 14, 2012. Maliksi then filed a petition for certiorari with the Supreme Court, reiterating his objections to the recount process. On March 12, 2013, the Supreme Court dismissed his petition, concluding that...