Case Summary (G.R. No. 250584)
Procedural Background
Upon the Regional Trial Court's (RTC) dismissal of Lloren's election protest for insufficiency in form, content, and failure to pay the cash deposit, Lloren filed an appeal and initially paid a total of P1,000.00. However, when he submitted the subsequent appeal fee of P3,200.00 to the COMELEC after the notice of appeal, the COMELEC First Division dismissed the appeal, stating Lloren did not pay the fee within the prescribed period. Lloren's motion for reconsideration was similarly denied by the COMELEC En Banc on the grounds of not paying the motion fee on time.
Issues Raised
Lloren contends that he complied with the payment requirements and that the delays were merely administrative. On the other hand, Pua argues Lloren's late payments justified the COMELEC's dismissal of the appeal, asserting that procedural compliance is non-negotiable.
Ruling on Procedural Issues
The court found in favor of Lloren regarding the procedural issue, emphasizing that he timely perfected his appeal. The unique rules governing election appeals necessitate distinct fees at both the RTC and COMELEC, which sometimes generates confusion. The key ruling clarifies that Lloren met the procedural deadlines for appeal and payment despite the COMELEC's reliance on outdated regulations that did not consider the revised appeal fee structure reported in Resolution No. 8486.
Ruling on Substantive Issues
While affirming the procedural merit of Lloren's case, the court upheld the RTC's initial dismissal of the election protest based on the merits, noting deficiencies in Lloren's protest submissions. Specifically, he failed to provide required details regarding precincts and the nature of fraud claims. Such omissions rendered his protest insufficient
...continue readingCase Syllabus (G.R. No. 250584)
Background of the Case
- This case involves a special civil action for certiorari filed by Bienvenido William D. Lloren against the Commission on Elections (COMELEC) and Rogelio Pua, Jr.
- The case arose from an election protest filed by Lloren following the May 10, 2010 automated elections, where Pua was proclaimed the winning candidate for Vice-Mayor of Inopacan, Leyte, with a plurality of 752 votes.
- Lloren alleged various electoral irregularities, including vote-buying and defective voting machines, prompting him to file Election Protest Case No. H-026 in the Regional Trial Court (RTC) of Hilongos, Leyte.
Initial Proceedings
- The RTC dismissed Lloren's election protest on November 12, 2010, citing insufficiencies in form and content and failure to pay the required cash deposit.
- Lloren filed a notice of appeal on November 17, 2010, and paid an appeal fee of ₱1,000.00 to the RTC.
- He subsequently remitted the required appeal fee of ₱3,200.00 to the COMELEC by postal money order on December 2, 2010.
Dismissal of Appeal
- On January 31, 2011, the COMELEC First Division dismissed Lloren's appeal due to failure to pay the appeal fee within the prescribed period.
- Lloren's motion for reconsideration was denied by the COMELEC En Banc on March 16, 2011, also on grounds of non-payment of the motion fee.
Issues Raised
- Lloren contended that he timely filed his notice of appeal and paid the necessary fees.
- P