Case Summary (G.R. No. 188747)
Background Facts
After the election concluded, the Office of the Election Officer of Dinalupihan issued Payumo a certified copy of the printed Certificate of Canvass of Votes and Proclamation (COCP) dated May 15, 2013. Payumo lodged an election protest on May 27, 2013, claiming fraud and irregularities which he asserted invalidated the election results. Payumo contended that his protest was timely, given that the proclamation date indicated in the printed COCP was May 15, 2013. Garcia countered that she was actually proclaimed on May 14, 2013, based on a manual COCP, thus asserting that Payumo had filed his protest beyond the required ten-day period.
Ruling of the Regional Trial Court
The Regional Trial Court (RTC) upheld Garcia's assertion, finding that her proclamation occurred on May 14, 2013. Consequently, on February 17, 2014, the RTC dismissed Payumo's protest, declaring it filed out of time as it fell beyond the ten-day reglementary period mandated by A.M. No. 10-4-1-SC rules. The RTC's order indicated its reliance on testimonies from the Municipal Board of Canvassers (MBOC) verifying Garcia's proclamation date.
Rulings of the Commission on Elections
Payumo appealed the RTC’s dismissal to the Comelec. The Comelec First Division issued a resolution on September 10, 2014, reversing the RTC’s decision, asserting Payumo's good faith reliance on the official printed COCP that listed May 15, 2013, as his basis for filing the protest. Subsequently, on January 29, 2015, the Comelec En Banc upheld the First Division's ruling, emphasizing that it would constitute injustice to hold Payumo accountable for a proclamation date he had no knowledge of at the time of filing.
Main Issue
The central issue in this case centers on whether Payumo's election protest was filed within the designated timeframe. Garcia insists the correct start date for the ten-day period is May 14, 2013, while Payumo argues it is May 15, 2013, based on his receipt of the printed COCP.
Court's Ruling
The Supreme Court ruled in favor of the petition, reinstating the RTC's dismissal of Payumo's protest. It determined that Garcia was proclaimed the winner on May 14, 2013, supported by the testimonies from the MBOC. The Court affirmed that the date of proclamation is pivotal for commencing the ten-day window for filing electoral protests as stipulated in the applicable election contest rules.
Legal Framework
The Court referenced Rule 2, Section 7 of A.M. No. 10-4-1-SC, which stipulates that the election protest must be filed within a non-extendible ten-day period from the proclamation date. The Court stated that this time frame is jurisdictional and that any violation results in the ousting of the court’s jurisdiction over the case. It reiterated the importance of strict compliance due to the time-sensitivity of election procedures.
Clarification of Juri
...continue readingCase Syllabus (G.R. No. 188747)
Nature of the Case
- The case is a petition for certiorari filed under Rule 65 in conjunction with Rule 64 of the Rules of Court.
- The petitioner, Maria Angela S. Garcia, seeks to annul the September 10, 2014 and January 29, 2015 Resolutions of the Commission on Elections (Comelec).
- The assailed rulings reinstated the election protest of private respondent Jose Alejandre Payumo III and reversed the Regional Trial Court's (RTC) ruling that the protest was filed out of time.
Facts of the Case
- Maria Angela S. Garcia and Jose Alejandre P. Payumo III were candidates for mayor of Dinalupihan, Bataan, in the May 13, 2013 elections.
- Garcia was proclaimed the winner with 31,138 votes compared to Payumo's 13,202 votes.
- Payumo received a certified copy of the printed Certificate of Canvass of Votes and Proclamation (COCP) dated May 15, 2013.
- On May 27, 2013, Payumo filed an election protest alleging fraud and irregularities.
- Payumo claimed he had until May 25, 2013, to file the protest, and since that date was a Saturday, he filed on the next working day, May 27.
- Garcia countered that she was proclaimed on May 14, 2013, and thus the protest was filed late, beyond the 10-day reglementary period.
Ruling of the Regional Trial Court
- The RTC dismissed Payumo's protest on February 17, 2014, for being filed beyond the statute of limitations.
- The RTC relied on testimonies from members of the Municipal Board of Canvassers (MBOC), who confirmed Garcia's proclamation on May 14.