Title
Reforma vs. De Luna
Case
G.R. No. L-13242
Decision Date
Jul 31, 1958
The Supreme Court rules in favor of Leon Reforma in the Catanauan mayoral election dispute, invalidating 33 illegal ballots that were improperly counted for Macario de Luna.
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Case Digest (G.R. No. L-13242)

Facts:

  • The case involves Leon Reforma vs. Macario De Luna, G.R. No. L-13242, decided on July 31, 1958.
  • The dispute originated from the mayoral elections in Catanauan, Quezon, held on November 8, 1955.
  • Leon Reforma and Macario De Luna were the only candidates for mayor.
  • Reforma was initially proclaimed the winner with 1,607 votes against De Luna's 1,580, a majority of 27 votes.
  • De Luna contested the election results in the Court of First Instance of Quezon, challenging returns from several precincts.
  • Reforma countered by questioning returns from other precincts.
  • The lower court later declared Reforma the winner with 1,610 votes to De Luna's 1,580, a majority of 30 votes.
  • De Luna appealed to the Court of Appeals, which reversed the lower court's decision, declaring De Luna the winner with 1,616 votes against Reforma's 1,604.
  • Reforma filed a motion for reconsideration, arguing that 33 ballots counted for De Luna were invalid, and three valid votes for him were rejected.
  • The motion was denied, leading Reforma to file a petition for review.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of Leon Reforma, reversing the Court of Appeals' decision.
  • The Court held that the 33 ballots counted for De Luna were illegal and should not have been included in the vote tally.
  • Consequently, Reforma was declared the mayor-elect of Catanauan, Quezon, with a majority of 21 votes.

Ratio:

  • The Supreme Court determined that the 33 ballots were illegal as they did not meet the requirements of Section 149, paragraph 13 of the Revised Election Code, which states that votes cast in a space not designated for a candidate are void and considered stray votes.
  • The Court noted that the trial court had initially disregarded these ballots not due to their illegality but because no evidence was presented to challenge their validity.
  • The Supreme Court clarified that it is the court's responsibility to reject illegal ballots on its own initiative, regardless of formal evidence.
  • The Court emphasized the importance of maintaining the integrity of elections and the necessity of considering all relevant evidence.
  • As a result, the 33 votes were deducted from De Luna's total, leading to a final tally of 1,604 votes for Reforma against 1,583 for De Luna, affirming Reforma's election as mayor.

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