Case Summary (G.R. No. 176296)
Trial Court Decision
Fernandez contested the election results, filing an election protest (Election Case No. P-192) with the 4th Municipal Circuit Trial Court (MCTC) of Pandan-Caramoran. After proceedings, the MCTC ruled in favor of Fernandez on January 12, 2004, declaring her the duly elected SK chairman based on a revision of votes that showed her receiving 29 votes compared to Rodriguez's 24 votes.
COMELEC's Ruling
Unsatisfied with the MCTC's ruling, Rodriguez appealed to the COMELEC, which on December 4, 2006, rendered a resolution nullifying the MCTC's decision. The COMELEC determined that three ballots, previously counted for Fernandez, had been tampered by another person to falsely reflect votes for her. Thus, the COMELEC adjusted the tally to declare Rodriguez the winner by one vote (26 to 27) after deducting the fraudulent votes.
Motion for Reconsideration and Petition
Fernandez subsequently filed a motion for reconsideration, which was denied by the COMELEC on January 31, 2007, due to its late filing. Following this, Fernandez filed a petition for certiorari and prohibition, arguing that the COMELEC lacked appellate jurisdiction over SK elections decided by lower trial courts and claiming significant abuse of discretion in nullifying the MCTC's judgment.
Court's Dismissal of Petition
The Supreme Court dismissed Fernandez's petition, concluding that the issue was moot since the term for the contested SK position had expired. The extended term under Republic Act No. 9340 meant that the position would no longer exist for practical legal determination, rendering any court ruling without effect.
Issue of Jurisdiction
Despite dismissing the petition, the Court addressed the jurisdictional issue raised by Fernandez for the benefit of future cases. The 1987 Constitution grants COMELEC appellate jurisdiction over contests concerning elective barangay offici
...continue readingCase Syllabus (G.R. No. 176296)
Case Overview
- This case involves a petition for certiorari and prohibition filed by Indira R. Fernandez against the Commission on Elections (COMELEC) and Mark Anthony B. Rodriguez.
- The petition challenges the COMELEC's Resolution dated December 4, 2006, and Order dated January 31, 2007, regarding the election for the Sangguniang Kabataan (SK) chairman in Barangay Pandan del Sur, Pandan, Catanduanes.
Background of the Case
- During the synchronized barangay and Sangguniang Kabataan elections on July 15, 2002, Mark Anthony Rodriguez received 27 votes, while Indira Fernandez received 25 votes, making Rodriguez the declared winner.
- Fernandez filed an election protest (Election Case No. P-192) with the 4th Municipal Circuit Trial Court (MCTC) of Pandan-Caramoran, contesting the election results.
- The MCTC, after reviewing the evidence, ruled on January 12, 2004, in favor of Fernandez, declaring her the duly elected SK chairman with 29 votes against Rodriguez's 24 votes.
COMELEC Proceedings
- Rodriguez appealed the MCTC's decision to the COMELEC.
- On December 4, 2006, the COMELEC First Division nullified the MCTC's decision, asserting that three ballots were tampered to falsely represent votes for Fernandez instead of Rodriguez.
- The COMELEC's ruling adjusted the vote tally, resulting in 26 votes for Fernandez and 27 for Rodriguez, declaring Rodriguez the duly elected