Facts:

The case of Pajao vs. Provincial Board of Canvassers of Leyte revolved around the 1949 general elections in the Philippines, specifically for the office of Congressman for the third district of Leyte. Francisco M. Pajao and Filemon Saavedra were the rival candidates in this election. After the elections concluded on November 8, 1949, the Provincial Board of Canvassers of Leyte convened to canvass the returns, resulting in a proclamation on November 25 declaring Saavedra as Congressman-elect with a margin of 302 votes over Pajao. However, this decision was controversial because the board annulled and excluded election returns from several precincts based on Saavedra's claim that irregularities had occurred. At the heart of this exclusion was the fact that including those returns would have made Pajao the clear winner with a lead of nearly 2,000 votes. Unaware of Saavedra's proclamation but aware of the risk to his own election, Pajao filed a petition for mandamus in the C

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Facts:

Election Background and Contest

• In the general elections held on November 8, 1949, Francisco M. Pajao and Filemon Saavedra were rival candidates for Congressman representing the third district of Leyte.
• The provincial board of canvassers of Leyte conducted the canvass of returns and, on November 25, proclaimed Saavedra as Congressman-elect with a margin of 302 votes over Pajao.

Disputed Election Returns and Canvassing Procedure

• The board annulled and excluded election returns from certain precincts in the municipalities of Biloan, Malicbog, and Cabalian.
• Saavedra’s representation of irregularities in these precincts led to their exclusion, even though their inclusion would have resulted in Pajao obtaining a majority of nearly 2,000 votes.

Pajao’s Petition for Mandamus and Preliminary Relief

• Unaware of the proclamation declaring Saavedra the winner but cognizant of the potential jeopardy to his election, Pajao filed a petition for mandamus at the Court of First Instance of Leyte on the same day.
• The petition sought to compel the provincial board of canvassers to proclaim him as Congressman-elect and to enjoin them from proclaiming Saavedra.
• The court responded by issuing a writ of preliminary injunction, ordering the board “to refrain from proclaiming any candidate as, Congressman-elect for the Third District of the Province of Leyte, until further order.”

Intervention of the Commission on Elections

• With the proclamation frozen, Pajao denounced the board’s action by wiring the Commission on Elections.
• The Commission, deeming the board’s exclusion of returns illegal, set aside Saavedra’s earlier proclamation and directed the board to conduct a new canvass including all disputed returns.

Reactions and Subsequent Developments by the Board

• The provincial board reconvened but, at first, a majority of its members reaffirmed the proclamation of Saavedra.
• Following a threat of disciplinary action and a subsequent opportunity to comply with the Commission’s directive, the board reconvened on December 2.
• After a recanvass that included the previously excluded election returns, the board proclaimed Pajao as Congressman-elect.

Subsequent Motions and Legal Proceedings

• Three days later, Saavedra filed a motion in the mandamus case requesting:
• The annulment of Pajao’s proclamation.
• The holding of the board members in contempt of court until they reversed Pajao’s proclamation.
• Saavedra also filed a separate protest with the Electoral Tribunal of the House.
• In response, Pajao moved to have his petition for mandamus dismissed, arguing that the relief sought had already been rendered moot by his subsequent proclamation.
• The lower court, after hearing submissions, rendered a decision denying Saavedra’s motion for contempt and granting Pajao’s motion for dismissal.

Appeal to the Supreme Court

• Saavedra appealed the lower court’s decision to the Supreme Court.
• The central contention on appeal was whether the lower court improperly dismissed the petition for mandamus and whether the motion for contempt was wrongly denied.

Issue:

Whether the petition for mandamus became moot due to Pajao’s subsequent proclamation as Congressman-elect.

• Did the subsequent action taken by the provincial board render the mandamus petition purposeless?

Whether further judicial intervention in the election dispute, which had been effectively submitted to the Commission on Elections and the Electoral Tribunal, should be entertained.

• Is it proper for the courts to intervene in an election contest that is constitutionally assigned to the House Electoral Tribunal?

The propriety of prosecuting contempt proceedings against the members of the board within the context of an already resolved electoral controversy.

• Can a motion for contempt in a proceeding that has become basically moot be entertained on appeal?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)