Facts:

• Cesar G. Manalo (Petitioner) and Ernesto M. Miranda (Respondent) were candidates for Punong Barangay in Sta. Maria, Mabalacat, Pampanga during the October 25, 2010 elections.
• Out of 2,302 registered voters, 1,605 cast their votes.
• Miranda was initially proclaimed the winner with 344 votes against Manalo's 343 votes.
• On November 4, 2010, Manalo filed an election protest in the 6th Municipal Circuit Trial Court (MCTC) alleging irregularities, including misreading of ballots and misconduct by the Board of Tellers.
• Miranda denied the allegations and moved to dismiss the protest, claiming it was insufficient.
• The trial court ruled in favor of Manalo on May 24, 2011, declaring him the true winner with 344 votes to Miranda's 333 votes, and ordered Miranda to vacate his position.
• Miranda appealed to the Commission on Elections (COMELEC) and sought a temporary restraining order (TRO) against the trial court's ruling.
• COMELEC issued a TRO on July 8, 2011, leading to further proceedings, including a resolution on December 22, 2011, that granted Miranda's petition for certiorari and prohibited the execution of the trial court's decision.
• Manalo's motion for reconsideration was denied by the COMELEC En Banc on April 17, 2012, prompting him to file a petition for certiorari with the Supreme Court.

Issue:

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Ruling:

• The Supreme Court ruled in favor of Manalo, remanding the case to the 6th MCTC for immediate execution of its May 24, 2011 decision, and making the tempo...(Unlock)

Ratio:

• The Supreme Court found the COMELEC's issuance of a temporary restraining order inappropriate since Manalo had already assumed office, rendering the order moot.
• The Court held that the COMELEC erred in interpreting the trial court's special order regarding execu...continue reading