Case Summary (G.R. No. 26423)
Factual Background
The petitioner contended that the election returns from the Board of Canvassers indicated he received 874 votes, compared to Advincula's 915 votes. An election protest was initiated by Isidoro Martinez against Advincula, who ultimately was found to have received 845 valid votes following a recount. Santos filed a motion for reconsideration claiming he should be declared the candidate-elect based on a revised count which allegedly favored him with more votes than Advincula.
Legal Contention
The primary legal argument presented by the petitioner was that the election court acted without jurisdiction, as it declared Advincula the winner despite Santos's higher adjudicated vote count. Santos argued that he should have been declared the candidate-elect based on both the original and reconsidered ballots, while the respondents maintained that Santos's failure to contest the original findings of the protest amid the proceedings eliminated his standing.
Respondents’ Defense
The respondents posited that Santos did not formally contest the protest results but rather failed to appear or present any evidence in his favor, thereby implicitly denying the allegations of vote counts against him. They also cited the rejection of 444 votes that were adjudicated to Santos by the election inspectors due to various objections raised during the hearings, asserting this reduced his valid votes significantly.
Court's Position on Jurisdiction
The court recognized that it must address the election results due to the nature of the protest and Santos's vested interest as a candidate. It opined that regardless of Santos's technical non-participation in the protest, it was incumbent upon the court to ascertain the accurate vote tallies and confirm whether or not he was indeed the candidate-elect.
Findings of Ballots
After reassessing the ballot counts during the motion for reconsideration, the court acknowledged errors regarding the inclusion of some ballots favoring Santos. Consequently, the court concluded that after ded
...continue readingCase Syllabus (G.R. No. 26423)
Case Background and Purpose
- The action originated from a petition filed by Rosendo E. Santos seeking a writ of certiorari to compel the Court of First Instance of Cavite to forward the records of election protest No. 1747 to the Supreme Court.
- The petitioner claimed that the court proclaimed Francisco Advincula as the candidate-elect for municipal president illegally and beyond its jurisdiction.
- Santos requested that the decision be annulled and that he be declared the rightful candidate-elect with a plurality of votes over Advincula.
Election Results and Contestation
- The election returns indicated the following votes for municipal president:
- Rosendo E. Santos: 874 votes
- Francisco Advincula: 915 votes
- Isidoro E. Martinez: 903 votes
- Tomas E. Diaz: 233 votes
- Following the election, Isidoro Martinez contested Advincula's election, with all candidates notified of the protest.
- The court's findings after hearing the protest revealed:
- Martinez received 828 votes.
- Advincula received 845 votes, leading to his declaration as the candidate-elect by a plurality of 17 votes.
Motion for Reconsideration
- On April 8, 1926, Santos filed a motion for reconsideration, asserting that a judicial canvass revealed he had a plurality of 29 votes over Advincula.
- The court denied this motion on July 27, 1926, stating that the decision was rendered without jurisdiction since Advincula o