G.R. No. 52793 - Sevilleja vs. Commission on Elections

Felipe M. Sevilleja was the certified Nacionalista Party (NP) candidate for mayor of San Manuel, Pangasinan in the January 30, 1980 elections.
Laureano Perez ran as the Kilusang Bagong Lipunan (KBL) candidate for mayor, while Francisco Asuncion, Jr. and Alejandro Tuvera were independent candidates for mayor and vice-mayor, respectively.

On January 15, 1980, respondents Asuncion and Tuvera filed a petition (PDC Case No. 117) with the Commission on Elections (COMELEC) to disqualify Sevilleja on the ground of turncoatism.

The petition alleged that Sevilleja was a former KBL member who changed his affiliation to the NP within the six-month period preceding the election.
Attached evidence included affidavits (e.g., that of Juan Sicam) and documentary exhibits regarding Sevilleja’s involvement with the KBL.

Sevilleja filed a verified answer denying any affiliation with the KBL and asserting a continuous political history with the NP, supported by documentary evidence and affidavits by his party officials.

COMELEC conducted a hearing on January 21, 1980, where both parties presented their evidence.

Private respondents submitted multiple exhibits (Exhibits “A”, “A-1” to “A-5”, “C-1”, “C-2”, “D”, etc.) to demonstrate Sevilleja’s participation in KBL activities.
Petitioner Sevilleja presented his own documentation, including his certificate of candidacy, NP candidate list approved by the NP Provincial Chairman, and additional affidavits.

In the hearing, COMELEC admitted evidence from both sides despite objections from Sevilleja’s counsel regarding the attachment and form of the exhibits submitted by the private respondents.

On January 28, 1980, COMELEC issued Resolution No. 8532 in PDC Case No. 117, effectively cancelling Sevilleja’s certificate of candidacy on the ground that he committed turncoatism by changing political affiliation within the prohibited period.
Following the resolution, on January 29-30, 1980, Sevilleja filed a motion for clarification and/or reconsideration, while a telegram directed the substitution of his candidacy with that of Asuncion.
On February 1, 1980, the Municipal Board of Canvassers, after receiving instructions based on the telegram and COMELEC’s resolution, proclaimed Laureano Perez as mayor-elect despite Sevilleja having secured the highest number of votes according to certifications.
On February 5, 1980, the municipal building, containing ballot boxes and other electoral records, was burned, complicating the election’s aftermath.
Sevilleja then pursued judicial remedies by filing an election protest (Civil Case No. U-3448) with the Court of First Instance and, subsequently, petitions for certiorari and other writs challenging the COMELEC resolutions in cases G.R. Nos. 52793 and 53504.

Petition G.R. No. 52793 sought certiorari, mandamus, and quo warranto to annul the proclamation of Perez and to have Sevilleja recognized as the duly elected mayor.
Petition G.R. No. 53504 aimed at reviewing on certiorari the COMELEC Resolutions (including the resolution dismissing Sevilleja’s disqualification challenge), alleging grave abuse of discretion in handling the candidacy and evidentiary matters.
Petitioner raised multiple assignments of error including:

The admission of documents by COMELEC despite procedural defects.
The finding of turncoatism based on the alleged evidence of affiliation with the KBL.
Failure to give due course to his certificate of candidacy despite his numerical lead in the vote count.

Admitting the private respondents’ evidentiary exhibits despite alleged procedural faults.
Concluding that Sevilleja was a former KBL member and therefore committed turncoatism by switching to the Nacionalista Party.
Cancelling Sevilleja’s certificate of candidacy based on the findings of change in party affiliation within the prohibited six-month period.

Whether Sevilleja’s subsequent remedial petitions (including the petitions for certiorari and election protest) were premature or barred by jurisdictional rules, given that:

The resolution cancelling his candidacy was final and executory pursuant to the 1978 Election Code.
The lower court had already acquired jurisdiction over the matter through the filed election protest.

Whether the alleged discrepancies in the vote certifications and the destruction of electoral records (due to the burning of the municipal building) should affect the validity of COMELEC’s resolutions and the proclaimed result.