Title
Tagoranao vs. Commission on Elections
Case
G.R. No. L-28598
Decision Date
Mar 12, 1968
1967 Marantao mayoral election contested due to fraud allegations; Comelec annulled Tagoranao's proclamation, favoring Mangondato. Supreme Court upheld most rulings but reinstated precinct 2 votes, ordering a new canvass.

Case Summary (G.R. No. 37661)

Election Disputes Arise

Following the elections, Cornell, representing the Liberal Party, petitioned the COMELEC on November 15, 1967, alleging fraud and terrorism, specifically that Tagoranao's supporters had seized and manipulated ballots. The COMELEC responded by suspending the canvassing process. Despite this, the municipal board of canvassers continued and proclaimed Tagoranao as the mayor-elect. Subsequently, the COMELEC annulled this proclamation.

Further Petitions and Actions

Mangondato, another Nacionalista Party candidate, filed a subsequent petition on December 12, 1967, seeking to annul Tagoranao's proclamation, calling it a violation of the COMELEC’s order and alleging the returns from certain precincts were fraudulently manufactured. Tagoranao opposed this petition, pointing to an earlier action he had initiated in the Court of First Instance concerning the election returns and arguing that Mangondato's request was duplicative.

Ongoing Legal Maneuvering

Cornell also filed a petition on December 20, 1967, focused on the rejection of returns from specific precincts, asserting that the counting of votes had not complied with the election law. Tagoranao contested this, affirming the counting procedures were valid. On January 3, 1968, the COMELEC upheld its earlier annulment of Tagoranao's proclamation while rejecting Cornell's petition regarding other precincts but supporting Mangondato's request regarding the fabrication claim for one precinct.

Subsequent Appeals and Jurisdiction Issues

Both Tagoranao and Cornell filed for certiorari, prohibition, and mandamus based on the COMELEC's decisions. Cornell argued that invalid registrations rendered the votes void ab initio, while the COMELEC maintained it did not possess jurisdiction to determine the validity of votes in the face of ongoing election-related disputes. Essential to the court's later decision was the determination of whether election returns could be deemed "obviously manufactured."

Examination of Election Returns

The COMELEC identified clear discrepancies in the returns from precinct 2, including statistical anomalies that suggested severe irregularities indicating the return was fabricated. It highlighted the impossibility of more votes being cast than there were registered voters and cited procedures followed for safeguarding elections under the conditions of violence in the Lanao region.

Court's Final Ruling

The court concluded that the COMELEC’s decisions to reject the

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