G.R. No. L-69932 - Calimbas vs. Commission on Elections

The case involves a petition for certiorari filed by Antonio S. Calimbas against the Commission on Elections (COMELEC) and Armando M. Quimlat.
The petition seeks to overturn a COMELEC decision from January 15, 1985, which declared Quimlat the duly elected Municipal Mayor of Morong, Bataan, reversing a prior ruling by the Court of First Instance that had proclaimed Calimbas as the winner.
The local elections in question took place on January 30, 1980, with three candidates: Calimbas (KBL), Quimlat (NP), and Benjamin Escolango (NUL).

Calimbas was initially proclaimed the winner with 2,545 votes, while Quimlat received 2,103 votes, resulting in a plurality of 442 votes.
Quimlat filed an election protest on February 7, 1980, alleging fraud, vote-buying, and irregularities in Voting Centers 1 and 2.
The trial court ruled in favor of Calimbas on March 17, 1982, affirming his election as the duly elected mayor with a plurality of 113 votes.

Quimlat appealed the trial court's decision to the COMELEC, which on January 15, 1985, nullified the votes from Voting Center No. 1 due to findings of 151 excess votes.
The COMELEC's ruling declared Quimlat the winner with 1,762 votes against Calimbas's 1,719 votes, a plurality of 43 votes.
Calimbas's motion for reconsideration was denied, prompting him to seek relief from the Supreme Court.

On February 21, 1985, the Supreme Court issued a Temporary Restraining Order preventing COMELEC from enforcing its decision and Quimlat from assuming office.
The primary issue for resolution was whether COMELEC abused its discretion in determining the existence of excess votes in Voting Center No. 1.

The Supreme Court found the data regarding excess votes to be confusing and inconsistent.
The Court noted that the COMELEC's assumption that "registered voters" equated to "actual voters" was erroneous.
The Court emphasized the need for accurate data on registered voters to determine the legitimacy of the excess votes claim.

The COMELEC's computation indicated 380 votes cast, but it erroneously stated that only 229 voters were registered.
The Court clarified that the number of registered voters and the number of actual voters are not synonymous.
The accurate figures showed that there were no excess votes, as the number of ballots found in the ballot box matched the number of votes cast.

The Court rejected Quimlat's assertion that the List of Registered Voters was spurious, affirming its status as an official document used during the elections.
The Court criticized the COMELEC for failing to obtain ...continue reading