Case Digest (G.R. No. 183399)
Facts:
The 1995 mayoralty election of Meycauayan, Bulacan, held on May 8, 1995, involved principal candidates Florentino P. Blanco and Eduardo A. Alarilla, with Blanco obtaining 29,753 votes and Alarilla 23,038 votes. Edgardo C. Nolasco was elected Vice-Mayor with 37,240 votes. The following day, May 9, 1995, Alarilla filed a petition with the Commission on Elections (COMELEC) to disqualify Blanco, alleging that Blanco maintained a private army armed with unlicensed firearms and engaged in massive vote-buying involving P10 million in cash given to teachers and election watchers to influence voters. The petition cited a police raid conducted pursuant to search warrants that allegedly uncovered evidence supporting these claims, including firearms and money, along with testimonies and affidavits from witnesses and victims of vote-buying and flying voters (individuals impersonating registered voters). Alarilla claimed Blanco violated Section 68 of the Omnibus Election Code by giving money
Case Digest (G.R. No. 183399)
Facts:
- Election and Candidates
- The mayoral election for Meycauayan, Bulacan was held on May 8, 1995.
- The principal candidates were Florentino P. Blanco and Eduardo A. Alarilla.
- Blanco received 29,753 votes, Alarilla 23,038 votes, and a third candidate, Mauro SC del Rosario, received 6,359 votes.
- Edgardo Nolasco was elected Vice-Mayor with 37,240 votes.
- Petition to Disqualify Blanco
- On May 9, 1995, Alarilla filed a petition to disqualify Blanco with the Commission on Elections (COMELEC).
- Allegations included Blanco maintaining a private army at his residence.
- A search warrant was issued on May 5, 1995, leading to a raid by an elite composite team of PNP Intelligence, backed up by the Special Action Force.
- The raid resulted in the arrest of six men carrying unlicensed high-powered firearms.
- Blanco’s Galil assault rifle was sighted inside a closed room, prompting the issuance of a second search warrant.
- Blanco’s wife and brother were allowed to withdraw ten large plastic bags from a vault inside that room.
- The bags contained shoe boxes with pay envelopes totaling P10,000,000.00, allegedly intended as bribe money for teachers of Meycauayan.
- The pay envelopes had the inscription “VOTE!!! TINOY,” reflecting a massive vote-buying scheme.
- The vote-buying scheme was organized through “MTB” (Movement for Tinoy Blanco Volunteers), chaired by Blanco’s brother Mariano.
- Evidence of flying voters paid to impersonate legitimate voters was also presented.
- Allegations included vote buying, terrorism to enhance candidacy, and overspending beyond lawful limits.
- Alarilla filed a motion to suspend Blanco’s proclamation, granted by the COMELEC First Division pending resolution of the disqualification.
- Proceedings before the COMELEC
- Blanco filed a motion to lift the suspension and filed an answer to the disqualification petition.
- Both parties submitted position papers; Blanco filed a reply.
- On August 15, 1995, the COMELEC First Division disqualified Blanco for vote-buying under Section 261(a) of the Omnibus Election Code.
- Blanco moved for reconsideration before the COMELEC en banc; Nolasco intervened, claiming he should be declared mayor in the event of Blanco’s disqualification.
- The COMELEC en banc denied motions for reconsideration on October 23, 1995.
- Petitions for Certiorari to the Supreme Court
- Blanco contended that the suspension and disqualification were made without due process, violated COMELEC procedural rules, and improperly awarded proclamation to the second placer.
- Nolasco petitioned for a declaration as mayor pursuant to the Local Government Code following Blanco’s disqualification.
Issues:
- Whether Blanco was denied due process by the COMELEC when his proclamation was suspended before a full hearing.
- Whether the COMELEC violated its own resolution (Resolution No. 2050) and Blanco’s right to equal protection by handling his disqualification case differently from other cases.
- Whether the use of summary proceedings by COMELEC to resolve Blanco’s disqualification was proper.
- Whether there was substantial evidence to support Blanco’s disqualification for vote-buying.
- Whether the second placer, Alarilla, may be proclaimed mayor in case of Blanco’s disqualification.
- Whether the Vice-Mayor, Nolasco, should be declared mayor upon Blanco’s disqualification under the Local Government Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)