G.R. No. L-32683 - Obando vs. Regis

Buenaventura Obando, the petitioner, is a protestee challenging the proclaimed election results.
The respondent, Urbano Regis, along with other protestants, were initially declared elected in the municipal elections held in Naga, Cebu on November 14, 1967.
The controversy involved multiple candidates for different positions, including the vice-mayor and councilors.

The election protest was initially filed by Urbano Regis and other candidates (Segundo Canonigo, Gilbert Repunte, Filemon Paunil, Demetrio Sayaang, Cornelio Patalinghug, Anastacio Canalita, Rodolfo Novales) against the declared winners which included protestee Buenaventura Obando.
In handling the protest, the court adopted a procedure that required both protestants and protestees to submit written statements listing the ballots objected to and claimed in the various precincts.
After the submission of these statements and replies, the Court of First Instance proceeded to decide the protest and established the principles allegedly applicable to resolving the issues of contested ballots.

The trial court tabulated the number of contested ballots credited to each party in each precinct.
The decision included a general explanation of the criteria for accepting or rejecting ballots—for example, ballots with figures before or after candidates’ names were noted as potentially invalid if used as a distinguishing mark.
The action taken by the court was to merely summarize the results by providing a table indicating the number of votes per precinct for each party, without specifically detailing which ballots were rejected or allowed, nor the reasons for each determination.

Protestee Buenaventura Obando filed a motion for reconsideration and new trial, arguing that the procedure adopted by the court failed to enable interested parties to identify the specific ballots objected to and to verify the correctness of the vote count in each precinct.
The trial court denied the motion on the ground that enumerating details on each ballot would unnecessarily lengthen the decision.

Obando elevated the case to the Supreme Court, reiterating his objection to the method used by the trial court.
He asserted that the decision was contrary to law, specifically violating Section 1 of Rule 36 of the Revised Rules of Court, which requires that judgments clearly and distinctly state the facts and the law upon which they are based.
The petitioner argued that the lack of specificity deprived the parties of the ability to determine whether the ballots were correctly adjudicated or whether errors had occurred.

The Supreme Court noted that the trial court’s decision failed to provide a clear, distinct statement of the facts and applicable law.
The absence of details regarding the acceptance or rejection of individual or groups of contested ballots rendered the decision incomplete.
This deficiency left the decision unreviewable, as appellate courts could not determine if the lower court’s resolution was consistent with legal principles and established jurisprudence.

Whether the trial court’s decision conformed to Section 1 of Rule 36 of the Revised Rules of Court by clearly stating the facts and law underlying the resolution of the contested ballots.
Whether the method of tabulating the contested ballots—without specifying the ballots rejected or accepted and the corresponding reasons—rendered the decision incomplete and unreviewable.
Whether the failure to provide a detailed analysis of the contested ballots deprived the parties of the opportunity to determine the correctness and acceptability of the court’s adjudication.