Case Summary (G.R. No. 120318)
Allegations by the Petitioner
Canicosa contested the election results, alleging widespread election fraud including vote tampering, intimidation, and procedural irregularities such as delayed delivery of election materials. He specifically claimed several grounds including:
- Inconsistency between the names of registered voters and those listed in precincts.
- Unregistered individuals voting in place of registered voters.
- Being credited with fewer votes than the number received.
- Incomplete control data on election returns.
- Unsecured ballot boxes during transport.
- Delays in the transmission of election documents.
Decision of the Commission on Elections
The COMELEC en banc dismissed Canicosa's petition for a declaration of failure of election, stating that the grounds cited did not justify such a declaration under Section 6 of Batas Pambansa Blg. 881, known as the Omnibus Election Code. This provision outlines specific criteria under which a failure of election may be declared: elections not held, suspensions prior to closing, or failures during the vote counting process.
Legal Framework for Failure of Election
The law stipulates that to declare a failure of election, allegations must fit into specific instances of egregious misconduct or irregularities that affect the electoral outcomes. Canicosa's claims did not align with these statutory exceptions, especially since he failed to demonstrate that the alleged irregularities had materially affected the overall election results.
Challenges to Voter Eligibility
Canicosa's complaint that registered voters could not vote while strangers did, was ruled as not sufficient grounds for declaring a failure of the election. Additionally, he had the option to appoint watchers to challenge any illegal voters and to raise issues before the Municipal Board of Canvassers, steps he did not take.
Registration of Voters
The issue regarding the names of registered voters not appearing on precinct lists is designated a matter for regular courts rather than the COMELEC. Section 138 of the Omnibus Election Code grants municipal and metropolitan trial courts exclusive jurisdiction over cases concerning the inclusion and exclusion of voters.
Administrative Versus Adjudicatory Functions of COMELEC
The petitioner argued that the COMELEC made an error by directly ruling on his petition instead of having it initially heard by a division. However, the Supreme Court clarified that the issues raised were largely administrative in nature. Thus, the COMELEC, acting in its administrative capacity, was within its rights to dismiss the petition for failure to justify the claim of election misconduct.
Proper Channels for Grievances
The Court elucidated that Canicosa should have pu
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Case Overview
- Ricardo "Boy" Canicosa and Severino Lajara were candidates for the mayoralty of Calamba, Laguna in the elections held on May 8, 1995.
- Lajara won the election by a margin of approximately 24,000 votes and was proclaimed by the Municipal Board of Canvassers.
- Canicosa subsequently filed a petition with the Commission on Elections (COMELEC) seeking to declare a failure of election and to nullify the canvass and proclamation based on alleged widespread electoral fraud and irregularities.
Allegations by Canicosa
- Canicosa claimed various electoral anomalies including:
- Names of registered voters missing from precinct lists.
- Over half of legitimate voters being unable to vote, with strangers casting votes in their stead.
- Being credited with fewer votes than actually received.
- Incomplete control data on election returns from some precincts.
- Unsecured ballot boxes delivered to the Municipal Treasurer's office.
- Delays in the delivery of election documents.
COMELEC's Dismissal of the Petition
- The COMELEC en banc dismissed Canicosa's petition, stating that his allegations did not meet the legal criteria for declaring a failure of election.
- The relevant law, Section 6 of Batas Pambansa Blg. 881 (Omnibus Election Code), outlines specific circumstances under which a failure of election can be declared, none of which were satisfied by Canicosa's claims.
Legal Framework
- Criteria for Declaration of Failure of Election:
- An election must not have been held due to force majeure, violence, terrorism, fraud, or similar causes.
- El