G.R. No. L-1776 - Cea vs. Court of Appeals

The case involves election protests arising from the January 30, 1980 local elections in Marawi City, Lanao del Sur.
Contestants represented two major political groups:

The Kilusang Bagong Lipunan (KBL) – with candidates such as Mahadi M. Pimping (official candidate for Vice-Mayor) and others for the Sangguniang Panglungsod.
The Nacionalista Party (NP) – represented by candidates including Salam N. Pangadapun (official candidate for Vice-Mayor) and additional candidates contesting for city and legislative positions.

Petition filed by Mahadi M. Pimping against the Commission on Elections (COMELEC) and Salam N. Pangadapun regarding the Vice-Mayor’s contest.
Petition filed by Habib Ali, Ombra Tomawis, Uttoh Banisil, Salem Nor, and Ibrahim Didaagun against the COMELEC and NP candidates regarding the Sangguniang Panglungsod seats.
Petition filed by Rashid D. Sampaco questioning the declaration of Omar M. Dianalan as City Mayor, wherein Sampaco alleged that 23 additional voting centers’ returns should have been annulled.

The three separate petitions were consolidated by the Court, reflecting the common contention over election irregularities.
COMELEC, in its Resolution dated January 7, 1985, declared null and void the election and election returns in 43 voting centers on the basis of overwhelming evidence of fraud and widespread irregularities.
The evidence included affidavits, expert testimony, and detailed examination reports (notably by handwriting and fingerprint expert Martin S. Ramos).

Fraudulent manipulation of votes;
Use of illegal identification, tampering and/or manufacture of ballots and returns;
Widespread vote-buying, intimidation, coercion, and violence; and
Substitution of voters and other procedural irregularities.

The evidentiary record relied heavily on the expert report, which described “overwhelming, convincing and direct” evidence in 43 voting centers.
The pre-proclamation case (docketed as Case No. 175) had been dismissed earlier, although its dismissal was noted as not prejudicial to filing an election protest.

COMELEC denied the motions for reconsideration (notably on January 29, 1985), declaring its decisions final and executory.
Despite petitions requesting a revision or recount of ballots in certain voting centers, COMELEC limited its annulment to the 43 voting centers where evidence was conclusively damaging.
The issue of whether to extend annulment to an additional 23 voting centers, as argued by petitioners (especially petitioner Sampaco), became a central matter in the dispute.

Whether the frauds, irregularities, and other election irregularities alleged were sufficiently flagrant and massive to warrant nullification of the election in and the election returns from 43 voting centers.
Whether the evidence presented with respect to 23 additional voting centers was adequate to declare those returns void as well.

Whether COMELEC, by not ordering a revision or recount of ballots in the 23 contested centers, committed grave abuse of discretion.
Whether the parties were given sufficient notice and opportunity to be heard, particularly in relation to the promulgation process of COMELEC’s resolutions (noting allegations that petitioners learned of the decisions via the newspapers).

Whether the rule declaring COMELEC’s decisions final and executory within 10 days, as contained in its Resolution No. 1450, conflicts with the constitutional guarantee of a 30-day period for appeal.
Whether the Court should intervene in the discretionary powers of COMELEC concerning evidence appraisal and ordering revisions of ballots.