Case Summary (G.R. No. L-13242)
Procedural History
After the general elections, Reforma was proclaimed the winning candidate with 1,607 votes against De Luna's 1,580 votes. De Luna challenged the election result in the Quezon Court of First Instance, disputing the vote counts from various precincts. Reforma subsequently filed a counter-protest regarding certain precincts as well. The trial court ultimately declared Reforma the mayor-elect with a confirmed plurality. However, upon appeal, the Court of Appeals found in favor of De Luna, reversing the lower court's decision and declaring de Luna the winner with a plurality of 12 votes.
Main Issues on Appeal
Reforma filed a motion for reconsideration on two counts, arguing that the Court of Appeals improperly counted 33 ballots where De Luna's name was not placed in the correct position for the mayoral vote, thus should have been counted as stray votes. Additionally, Reforma contended that the appellate court disregarded three valid votes cast for him.
Court Proceedings and Conduct
During the proceedings, the court had appointed commissioners to review and count the ballots. The commissioners identified the 33 ballots where De Luna's name was improperly marked, yet these ballots were not claimed by his attorney as valid votes during the trial. The trial court ultimately pronounced its decision without considering these ballots, citing Reforma's absence on the trial date as the reason for the default ruling in favor of Reforma.
Legal Basis for Count Validity
The Revised Election Code provides that votes cast for candidates not contesting particular offices should be considered stray and thus invalid. It mandates that such illegal votes should not be counted towards a candidate's total. There exists a strict protocol for ballot examination, facilitating judicial counting upon request, which must abide by the principles of justice and election validity.
Court of Appeals’ Rationale
The Court of Appeals held that, due to the lack of formal objection from Reforma to the inclusion of the contested ballots, they should be counted in favor of De Luna. The appellate body relied on the reasoning that since these ballots were found in the ballot box and not claimed as invalid at the trial, they automatically benefitted the candidate they were cast for.
Supreme Court's Analysis
The Supreme Court scrutinized the legality of the ballots and focused on whether the lack of presentation
...continue readingCase Syllabus (G.R. No. L-13242)
Case Summary
- In the general elections held on November 8, 1955, Leon Reforma and Macario De Luna were candidates for Mayor of Catanauan, Quezon.
- The initial vote count showed Reforma with 1,607 votes and De Luna with 1,580 votes, leading to Reforma's proclamation as mayor-elect by a majority of 27 votes.
- De Luna contested the election results in the Court of First Instance, challenging the correctness of the returns from several precincts while Reforma filed a counter-protest regarding votes from other precincts.
- The trial court ultimately declared Reforma the mayor-elect with 1,610 votes against De Luna's 1,580, resulting in a majority of 30 votes.
- De Luna appealed to the Court of Appeals, which reversed the lower court's decision, declaring De Luna the mayor-elect with 1,616 votes against Reforma's 1,604, establishing a plurality of 12 votes.
Grounds for Reconsideration
- Reforma filed a motion for reconsideration based on two main arguments:
- The Court of Appeals counted 33 ballots as valid votes for De Luna despite these ballots not having De Luna's name written in the designated space for mayor.
- The court rejected three valid ballots for Reforma.
Proceedings in Lower Court
- The trial court appointed three commissioners to revise the ballots.
- During the revision, the commissioners noted the 33 ballots where De Luna’s name was incorrectly