Case Summary (G.R. No. 204828)
Factual Background
Following the elections, Regio received 478 votes, defeating Co, who received 336 votes. Co contested the election results through a protest filed on November 4, 2010, citing several alleged irregularities in the electoral process, such as failure to adhere to COMELEC Resolution No. 9030, allegations of vote-buying, and the presence of flying voters. Ultimately, Co restricted his protest to five clustered precincts, with a focus on revising the ballots.
Trial Court Findings
The Metropolitan Trial Court (MeTC) conducted a revision of ballots, which revealed a substantial recovery of votes for Co. However, despite the revised results, the MeTC dismissed Co's protest in its decision dated May 4, 2011, affirming Regio's victory based on the presumption of regularity and the integrity of the original election returns. The court concluded that Co failed to prove any significant tampering or irregularities that would invalidate the election results.
COMELEC First Division Decision
Following the dismissal of his protest, Co appealed to the COMELEC's First Division, which upheld the trial court's ruling on August 23, 2011. The First Division reiterated that Co did not provide adequate evidence to prove that the integrity of the ballots was compromised. The absence of direct proof of tampering was noted as insufficient for overturning the official election results.
COMELEC En Banc Resolution
Co sought reconsideration of the First Division's ruling, which was initially denied. However, the COMELEC En Banc issued a resolution on December 7, 2012, overturning the earlier decisions and declaring Co as the duly elected punong barangay, citing the purported genuineness of the ballots in question. This reversal was anchored in a finding that no incidents affecting the preservation of the ballots occurred following the election.
Legal Issues Raised
The petitioner's arguments highlighted that the COMELEC En Banc had committed grave abuse of discretion by reversing the established rulings on inadequate evidence. The key legal issues involved whether the COMELEC properly assessed the integrity of the ballots and if it rightly prioritized the revision results over the original election returns.
Court's Ruling and Reasoning
The Court ruled that the case was moot following the assumption of office by a new set of barangay officials in November 2013, effectively rendering the dispute over the 2010 elections devoid of practical significance. Nonetheless, the Court identified grave abuse of discretion in the COMELEC En Banc&#
...continue readingCase Syllabus (G.R. No. 204828)
The Case
- This case involves a Petition for Certiorari filed under Rule 64, in relation to Rule 65, seeking to nullify and set aside the Resolution dated December 7, 2012, of the Commission on Elections (COMELEC) En Banc in EAC (BRGY-SK) No. 161-2011.
- The assailed Resolution reversed and set aside the earlier decision of the COMELEC First Division dated August 23, 2011, which affirmed the Decision in Election Case No. 02480-EC of the Metropolitan Trial Court (MeTC), Branch 4 in Manila.
The Facts
- Petitioner Jaime C. Regio and private respondent Ronnie C. Co participated in the October 25, 2010 barangay elections in Barangay 296, Zone 28, District III of the City of Manila for the position of punong barangay.
- Regio was proclaimed the winner, obtaining 478 votes compared to Co's 336 after counting and canvassing from seven clustered precincts.
- Co filed an election protest on November 4, 2010, alleging irregularities in the elections, including non-compliance with COMELEC Resolution No. 9030, vote-buying by Regio, and other electoral fraud claims.
- The initial protest included seven clustered precincts, but Co later excluded two from his protest.
- A revision of ballots occurred, revealing substantial changes in the vote count favoring Co, prompting him to present the revision report as evidence, while Regio denied any electoral fraud and claimed the ballots were tampered with post-election.
- The MeTC dismissed Co's protest on May 4, 2011, affirming Regio's election.
The MeTC's Decision
- The trial court emphasized that it needed to ascer