Case Summary (A.M. No. RTJ-16-2450)
Initial Court Proceedings
The election protest was heard in the Court of First Instance of Iloilo, where, after trial, Capalla was adjudicated to have received 782 valid votes to Tabiana's 756, resulting in a ruling that declared Capalla as the municipal president-elect by a margin of 26 votes. Tabiana appealed the ruling, and on May 18, 1935, the Supreme Court affirmed Capalla's election.
Motion for Reconsideration and New Trial
Following the Supreme Court's decision, Tabiana filed a motion for reconsideration, claiming the lower court failed to adjudicate certain ballots. On July 31, 1935, the Supreme Court granted a new trial specifically to address those unadjudicated ballots in precinct No. 4 of Leon, Iloilo, thus remanding the case to the trial court for further proceedings.
Outcome of the New Trial
On October 10, 1935, the trial court rendered a new decision, this time awarding Capalla 802 votes and Tabiana 820 votes, resulting in a new margin of 18 votes in favor of Tabiana. Capalla subsequently appealed this judgment.
Assignments of Error
Capalla presented multiple assignments of error:
- Jurisdiction Issue: He contended that the trial court lost jurisdiction to hear the case since the one-year period for resolving election contests had expired.
- Admission of Ballots: Capalla argued against the admission of 84 ballots in favor of Tabiana, asserting that their inclusion was erroneous.
- Counting of Allegedly Invalid Ballots: He alleged that 64 ballots counted for Tabiana were invalid and sought annulment of the election results in precinct No. 4 if the ballots could not be segregated.
- Final Declaration: Capalla contended the trial court erred by not declaring him the duly elected municipal president.
Rulings on Assignments of Error
- Jurisdiction Argument Rejected: Citing the precedent of Cacho vs. Abad, the Supreme Court ruled that the one-year limit on election contests does not apply to cases the Supreme Court has taken jurisdiction over, thereby overruling this assignment of error.
- Admission of Ballots: The 84 ballots were deemed appropriate for consideration during the new trial as they had not been previously adjudicated, leading to an overruling of this assignment as well.
- Invalid Ballots Count: The challenge to the validity of 64 ballots failed due to lack of proper identification and segregation; therefore, this assignment was also overruled. The court underscored that only extreme fraud warr
Case Syllabus (A.M. No. RTJ-16-2450)
Case Background
- In the general elections held on June 5, 1934, Jose G. Capalla and Ramon C. Tabiana were candidates for the office of municipal president of Leon, Iloilo.
- The municipal council proclaimed Ramon C. Tabiana as the elected candidate, with 836 votes against Capalla's 809.
- Jose C. Capalla filed a protest against Tabiana's election, focusing on precincts 1, 2, and 4, which were heard in the Court of First Instance of Iloilo.
Trial Court Findings
- After trial, the Court of First Instance found that Capalla had received 782 valid votes, compared to Tabiana's 756 valid votes, leading to Capalla being declared the president-elect with a majority of 26 votes.
- Tabiana appealed, and the Supreme Court's decision on May 18, 1935, confirmed Capalla's victory, noting he received 786 votes against Tabiana's 760.
Motion for Reconsideration
- Following the Supreme Court's affirmation, Tabiana's counsel filed a motion for reconsideration, claiming the trial court neglected to address 64 ballots.
- The Supreme Court, on July 31, 1935, ordered a new trial solely to adjudicate these ballots in precinct No. 4 and set aside its earlier decision.
Subsequent Trial Court Decision
- On October 10, 1935, the trial court adjudicated 802 votes to Capalla and 820 to Tabiana, resulting in an 18-vote majority for Tabiana.
- Capalla, now the protestant-appellant, appealed this de