Case Summary (G.R. No. 174620)
Election Results and Initial Dispute
Following the vote canvassing, the Barangay Board of Canvassers proclaimed Aldo B. Cordia as the winner, having secured 614 votes against Joel G. Monforte’s 609 votes. Subsequently, on July 18, 2002, Monforte filed an election protest with the Municipal Trial Court in Cities (MTCC) of Legazpi City, asserting that the Board of Election Tellers failed to credit him with ten votes due to their lack of familiarity with the rules governing ballot appreciation as per COMELEC Resolution No. 4846.
MTCC Ruling and Further Action
The MTCC conducted a recount and revealed results that overturned the previous election outcome: Monforte had 616 votes compared to Cordia's 614. Consequently, the MTCC declared Monforte the rightful winner and ordered Cordia to vacate the Punong Barangay office, along with a directive for Cordia to pay P6,350 in honoraria and expenses related to the Revision Committee.
Appeal and COMELEC's Decisions
Cordia appealed the MTCC's ruling and the Second Division of the COMELEC upheld the lower court's decision on August 14, 2003. A Motion for Reconsideration yielded a conformity of 5-1 by the COMELEC En Banc, leading to the eventual affirmation of the MTCC’s judgment and action for Monforte's swearing-in as the duly elected official on January 15, 2007.
Grounds for Petition for Certiorari
Cordia's petition for certiorari alleged that the COMELEC exercised grave abuse of discretion concerning the appreciation of certain ballots. Key contentions included the improper application of the neighborhood rule, misinterpretation concerning votes allegedly marked as “Mantete,” and the classification of a specific ballot as a mere ink smudge rather than a deliberate identification mark.
COMELEC's Interpretation of Voter Intent
The court affirmed that the primary objective of ballot appreciation is to determine the voter's intent with reasonable certainty. The COMELEC’s judgments regarding the marking of ballots, particularly the application of the idem sonans rule to “Mantete,” were not found to constitute grave abuse of discretion. The petitioner's argument that “Mantete” might refer to a candidate for kagawad lacked substantively convincing evidence, further validating the COMELEC's decision.
Consideration of the Neighborhood Rule
The ruling further clarified the neighborhood rule, which permits the recognition of miscast votes under specific circumstances as stipulated in Section 211 (19) of the Omnibus Election Code. This provision assists in preserving the integrity of
...continue readingCase Syllabus (G.R. No. 174620)
Case Background
- Aldo B. Cordia (petitioner) and Joel G. Monforte (respondent) were official candidates for Punong Barangay of Barangay 16 (East Washington) in Legazpi City, Albay during the synchronized Barangay and Sangguniang Kabataan elections held on July 15, 2002.
- Following the election, the Barangay Board of Canvassers proclaimed Cordia as the winner with 614 votes, narrowly defeating Monforte who received 609 votes.
Election Protest
- On July 18, 2002, Monforte filed an Election Protest with the Municipal Trial Court in Cities (MTCC) of Legazpi City, claiming the Board of Election Teller failed to credit him with ten votes due to unfamiliarity with the rules on ballot appreciation as outlined in COMELEC Resolution No. 4846.
- The MTCC ordered a recount which yielded a new result: Monforte received 616 votes, while Cordia had 614 votes.
MTCC Judgment
- The MTCC rendered a judgment in favor of Monforte, annulling Cordia's proclamation as the winner, declaring Monforte as the rightful Punong Barangay, and ordering Cordia to vacate the office.
- Cordia was also ordered to pay P6,350.00 for the honoraria of the Revision Committee and other expenses.
Appeals Process
- Cordia appealed the MTCC's decision. The Second Division of the Commission on Elections (COMELEC) affirmed the MTCC's ruling