Case Summary (G.R. No. 107854)
Election Proclamations and Initial Complaints
Petitioner Samad was proclaimed mayor-elect by a board led by Mucado M. Pagayao on May 29, 1992, while Abdula was proclaimed by another board, headed by Abas A. Saga, on May 28, 1992. The conflict prompted both candidates to file separate petitions with the Commission on Elections (COMELEC). On June 1, 1992, Samad sought to nullify Abdula’s proclamation and requested a special election, while Abdula filed a petition on August 14, 1992, to annul Samad’s proclamation and prevent him from assuming office.
COMELEC Actions and Court Decisions
The petitions were consolidated and assigned to the COMELEC's First Division. On June 29, 1992, COMELEC initiated an investigation into the situation and directed the involved election registrars to appear before the Commission. Additionally, it issued Resolution No. 2489, terminating most pre-proclamation cases, excluding those specifically listed—SPA 92-314 was not among them.
Petitioner subsequently filed a civil action for quo warranto and prohibition with a request for a preliminary injunction in the Regional Trial Court of Cotabato City which was initially dismissed due to jurisdictional doubts but later resulted in a temporary restraining order that favored Samad.
Legal Developments in the Regional Trial Court and COMELEC
Abdula challenged the court’s orders through a petition with the Court of Appeals, leading to several judicial reviews. However, COMELEC found both proclamations defective due to issues pertaining to the validity of certificates of canvass and the constitution of the boards. On November 4, 1992, COMELEC denied both petitions and instructed the creation of a Special Board of Canvassers to verify the votes.
Petition for Certiorari
Amid ongoing disputes, Samad filed a petition for certiorari with the Supreme Court, requesting to stop the implementation of COMELEC's controversial rulings. The temporary restraining order was issued on December 3, 1992, recognizing Samad as the duly elected mayor given the problematic proclamations.
Final Rulings and Jurisdiction Issues
After analyzing the jurisdictional claims, the Supreme Court rejected Abdula’s argument that SP 92-314 was terminated by COMELEC Resolution No. 2489, stating that the resolution allowed certain cases to remain active for review. The Supreme Court maintained that COMELEC and the Regional Trial Court both had jurisdiction over the claims, but since the matter involved election processes, primary jurisdiction rested with the COMELEC according to the Omnibus Election Code.
COMELEC's Lack of Authority
The Supreme Court held that the proclamations from both boards were null and void due
...continue readingCase Syllabus (G.R. No. 107854)
Background of the Case
- The case involves two consolidated petitions concerning the position of Mayor in Kabuntalan, Maguindanao.
- Petitioner Datu Sukarno S. Samad and private respondent Bai Unggie Abdula were rivals in the synchronized elections held on May 11, 1992.
- Both were proclaimed mayor-elect by different canvassing boards; Abdula was proclaimed by Abas A. Saga's board on May 28, 1992, while Samad was proclaimed by Mucado M. Pagayao's board on May 29, 1992.
Procedural History
- On June 1, 1992, Samad filed SPA 92-314 to nullify Abdula's proclamation and call for special elections in three precincts.
- Abdula filed SPC 92-421 on August 14, 1992, seeking to nullify Samad's proclamation and prevent him from assuming office.
- The cases were consolidated and assigned to the First Division of the COMELEC.
- On June 29, 1992, the COMELEC initiated an investigation into the conflicting proclamations and issued Resolution No. 2489 to terminate all pre-proclamation cases, except for specific enumerated cases.
Regional Trial Court Proceedings
- Samad filed a quo warranto and prohibition petition in the Regional Trial Court of Cotabato City, which initially denied jurisdiction but later issued a preliminary injunction against Abdula's assumption of office.
- Abdula contested this injunction by filing a petition with the Court of Appeals.
- On November 4, 1992, the COMELEC denied the consolidated petitions and directed the formation of a Special Board of Canvassers to resolve the authenticity of the conflicting proclamations.