Case Summary (G.R. No. L-6813)
Administrative Law and Election Law Context
- The Culion Leper Colony is recognized as a national reservation under the exclusive administrative control of the Department of Health.
- The Bicol Treatment Station, located in Cabusao, is established through an administrative order and remains part of the municipality of Cabusao.
- Lepers residing in the Bicol Treatment Station are considered residents of Cabusao for voting purposes, as there is no law separating them from the municipality.
- The ruling in Alcantara vs. Secretary of the Interior supports the notion that lepers can acquire residence for voting despite their confinement.
Voter Registration and Qualification Issues
- The claim that lepers voting in precinct No. 11 are residents of Libmanan lacks sufficient evidence and cannot be judicially noticed.
- The Board of Inspectors is presumed to have verified the qualifications of voters during registration.
- Any challenge to voter qualifications should have been raised during the registration period; failure to do so renders the issue moot.
- The corrected registry list is conclusive regarding voter eligibility in election contest proceedings, as mandated by the Revised Election Code.
Commission on Elections' Authority
- The Commission on Elections has the constitutional mandate to enforce election laws and supervise election-related officials.
- The Board of Canvassers has a ministerial duty to count votes and cannot question the validity of election returns.
- The exclusion of votes from precinct No. 11 by the Board of Canvassers was a failure of duty, justifying the Commission's directive to reconvene and include those votes.
- Any claims of exceeding authority by the Commission due to the elapsed protest period are waived if not challeng...continue reading