Title
Sema vs. House of Representatives Electoral Tribunal
Case
G.R. No. 190734
Decision Date
Mar 26, 2010
Election protest alleging irregularities dismissed; HRET relied on untampered election returns as ballots were fake or missing, affirmed by Supreme Court.

Case Summary (G.R. No. 190734)

Background of the Case

On June 12, 2007, petitioner Sema filed an election protest claiming that various Boards of Election Inspectors (BEIs) colluded with Dilangalen to miscount and misrepresent votes in favor of Dilangalen. Sema asserted numerous grounds based on alleged election fraud, including the use of bogus ballots, miscounting of valid votes as stray, and acts of intimidation against voters. Conversely, the respondent filed a counter-protest and raised allegations of similar electoral malpractice against Sema.

Proceedings and Findings

The House of Representatives Electoral Tribunal (HRET) conducted a revision of ballots from both the protested and counter-protested precincts between September 16 and 29, 2008. The tribunal found that 247 out of 248 ballot boxes from the counter-protested precincts were empty, undermining the integrity of the election process. The HRET later concluded that the evidence of spurious ballots raised questions about the validity of the votes but ultimately did not substantiate a claim of fraud that would necessitate overturning the election results.

HRET Decision

On September 10, 2009, the HRET issued a decision dismissing Sema's protest on the grounds that while many ballots were found to be fake or spurious, there was insufficient evidence to prove that the election itself was fraudulent. The Tribunal ruled that the integrity of the evidence (ballots and election returns) held substantial weight in concluding that Dilangalen was the duly elected representative.

Ruling on Reconsideration

Sema's subsequent motion for reconsideration was denied on November 12, 2009. She contended that the HRET had committed grave abuses of discretion by ruling against her despite overwhelming evidence of electoral fraud. Sema raised several points questioning the validity of the ballots counted for Dilangalen and claimed that the Tribunal failed to account for fraudulently introduced ballots.

Supreme Court Analysis

The Supreme Court found Sema's petition unmeritorious, emphasizing that it does not function as a trier of facts and should not interfere unless there is grave abuse of discretion. The Court reiterated that the HRET had the authority to rely on election returns and documents when ba

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