Case Digest (G.R. No. 126859)
Facts:
The case revolves around Representative Alvin S. Sandoval (Petitioner) and the House of Representatives Electoral Tribunal (HRET), alongside Josephine Veronique R. Lacson-Noel (Respondent) and Hon. Speaker Prospero Nograles. On May 19, 2007, after the canvass of votes, the Board of Canvassers proclaimed Sandoval as the winner in the elections for the member of the House of Representatives for the Lone District of Malabon City-Navotas, securing 71,490 votes compared to Lacson-Noel's 70,331 votes. The electoral process faced challenges when Lacson-Noel filed a petition on May 29, 2007, alleging several fraudulent activities and irregularities had occurred, affecting the election outcome in 623 precincts. These allegations included the miscounting of votes, the counting of invalid ballots, and manipulation of election returns, suggesting that a recount and revision of ballots was necessary to ascertain the true electoral outcome. Sandoval countered Lacson-Noel's claims, su
Case Digest (G.R. No. 126859)
Facts:
In the May 2007 congressional election for the Lone District of Malabon City-Navotas, the Board of Canvassers proclaimed Alvin Sandoval as the winning candidate with 71,490 votes over Josephine Veronique Lacson-Noel’s 70,331 votes. Protest arose when Lacson-Noel challenged the election results on allegations of widespread irregularities—including miscounting, misinterpretation, and manipulation of votes in 623 of the 1,437 precincts—claiming that fraudulent practices had deprived her of the correct number of votes.Sandoval, in his answer and counter-protest, denied these allegations and asserted that it was instead Lacson-Noel’s supporters who had committed irregularities that resulted in him being deprived of votes in 1,006 precincts. As the electoral protest proceeded, the House of Representatives Electoral Tribunal (HRET) undertook a comprehensive revision of ballots. The revised count ultimately produced 70,530 votes for Lacson-Noel against 69,939 for Sandoval.
Throughout the subsequent hearings—from September 2008 into early 2009—Sandoval repeatedly requested additional time to present his evidence, including motions for technical examination and the presentation of further witnesses. Despite being granted a final extension of ten days, Sandoval failed to complete his evidence presentation within the mandated timeframe under Rule 59 of the HRET Rules of Procedure. Consequently, the Tribunal ruled that he had waived his right to submit further evidence.
Issues:
- Whether the HRET erred in denying Sandoval’s request for additional time to present his formal offer of evidence and further documentary pieces.
- Whether the strict observance of the two‐month limit for evidence presentation, as required under Rule 59 of the HRET Rules of Procedure, resulted in a denial of due process to Sandoval.
- Whether the revision and recount of ballots, along with the limited evidentiary presentation, could have substantially affected the outcome of the contested election.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)