G.R. No. L-53619 - Sabeniano vs. Commission on Elections

Case Digest (G.R. No. L-53619)
Standard Advanced

Facts:

Parties and Background

Petitioners: Nacionalista Party official candidates for Mayor, Vice-Mayor, and members of the Sangguniang Panglunsod of Dagupan City.
Respondents:

Private respondents representing the Kilusan ng Bagong Lipunan (KBL) – official candidates in the January 30, 1980 local elections.
The respondent institutions include the Commission on Elections (COMELEC) and the City Board of Canvassers of Dagupan City.

Election and Canvassing Process

During the local elections held on January 30, 1980, votes were cast for various city positions.
The City Board of Canvassers completed its canvass on February 1, 1980 at 2:35 p.m. and immediately proclaimed the KBL candidates as the winners.
Official documents such as the “Certificate of Canvass of the Votes Cast and Proclamation of the Winning Candidates” detailed the vote totals for positions including:

Mayor – Respondent Manaois with 20,981 votes.
Vice-Mayor – Respondent Siapno with 20,194 votes.
Sangguniang Panglunsod members – Various vote totals as listed in the certificate and canvass sheets.

Petition and Subsequent Proceedings

On February 4, 1980, petitioners filed a petition with COMELEC (docketed as Election Case No. 238) alleging:

Lack of notice and undue haste in the canvassing and proclamation.
Tampering with, alterations, and falsification of election returns.
Other irregularities committed before, during, and after the elections.

COMELEC’s initial response:

On February 8, 1980, COMELEC suspended the effects of the proclamation of the private respondents.
A supplementary petition was filed by the petitioners on February 9, 1980, adding specific additional grounds.

Motion by Private Respondents:

On February 13, 1980, respondents filed a motion for reconsideration/annulment of the suspension, arguing that COMELEC lacked jurisdiction over a pre-proclamation controversy and that the petitioners’ allegations resulted from misrepresentation.

COMELEC Resolution No. 9102 (February 14, 1980):

Reinstated the original proclamation based on evidence of proper notice (such as a telegram-notice signed by the Election Registrar).
Directed that petitioners pursue remedies through election protests or quo warranto proceedings.

Further Motions by Petitioners:

An urgent motion for a permanent restraining order was filed on February 15, 1980.
A supplemental urgent motion for reconsideration followed on February 18, 1980.
An Ex-Parte Motion consolidating these pleas and seeking disqualification of private respondents was filed on February 21, 1980.

Alleged Discrepancies and Errors

Petitioners alleged significant irregularities in the canvassing process:

Claims of non-inclusion or tampering with election returns in certain voting centers (notably precincts numbered 57-A, 113, 176/195, and 215).
Contentions that discrepancies in figures (e.g., in Comelec Form No. 28-A) resulted in erroneously inflated vote totals for the winning candidates.
Detailed computation errors were pointed out, including typographical mistakes where commas were misprinted as the numeral “1”, thus recording votes as “31789” instead of “3,789” for respondent Manaois and “11093” instead of “1,093” for petitioner Sabeniano.

Petitioners argued that:

Such errors led to a total vote count (78,269) dramatically exceeding both the number of registered voters (approximately 52,268) and actual voters (43,092).
Correcting these discrepancies would show that petitioner Sabeniano had actually won by a clear majority.

Evidence and Counterarguments Presented

Respondents and the City Board of Canvassers testified that:

The so-called anomalies were a result of innocent typographical errors or addition mistakes, not deliberate tampering.
The minutes and certified canvass sheets reflected the corrected and proper sums (e.g., Manaois’ vote corrected to 20,981 and Sabeniano’s to 10,387 in the official record).

The issue of the proper application of election rules:

Notification procedures were followed as evidenced by telegram notices duly sent on January 24, 1980.
COMELEC relied on established provisions regarding the scheduling and conduct of the canvassing (referencing Sections 150 and 169 of the Election Code and Resolution No. 1418).

Final Background on Subsequent Actions

Additional election protests were subsequently filed by petitioners on February 29 and March 3, 1980, covering different aspects and allegations.
The overall controversy centered on whether the election was nullified due to procedural irregularities and alleged vote tampering, or whether the proper remedies under election protest rules had been exhausted.

Issues:

Whether petitioners successfully demonstrated a denial of due process in the canvassing of election returns, particularly regarding the notification and attendance of their representatives.
Whether the alleged irregularities and discrepancies in the election returns (such as numerical errors leading to excess vote counts) warrant the annulment of the election results.
Whether the remedy sought through a pre-proclamation petition was the proper legal avenue, given that the issues raised might have been more appropriately challenged through formal election protests.
Whether COMELEC abused its discretion by reinstating the proclamation of the private respondents despite the discrepancies alleged by petitioners.

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

Doctrine:

(Subscriber-Only)

Unlock Full Case Digest

Case Digest (G.R. No. L-53619) Concise

Facts:

Case Digest (G.R. No. L-53619) Standard Advanced

Facts:

Issues:

Ruling:

Ratio:

Doctrine:

Case Digest (G.R. No. L-53619)
Concise

Case Digest (G.R. No. L-53619)
Standard Advanced