Case Summary (G.R. No. 166931)
Case Background
This matter originates from the barangay elections held on July 15, 2002, in Sta. Ana, San Pablo City. Following the elections, Velasco was proclaimed the winner with 390 votes against Layesa’s 375. Layesa contested the results by filing an election protest, alleging that certain ballots in his favor were erroneously excluded in the canvassing process.
Trial Court Ruling
On August 23, 2002, the Municipal Trial Court ruled that the results were tied, declaring both candidates as having secured 390 votes each after revising contested ballots. The court directed a drawing of lots to decide the winner. Velasco appealed this decision to the Commission on Elections (COMELEC), claiming errors in the trial court's crediting of additional votes to Layesa.
COMELEC Second Division Ruling
On February 10, 2003, the COMELEC Second Division upheld the trial court’s ruling, applying the "neighborhood rule" in its appreciation of certain ballots. Both parties filed motions for reconsideration, with Velasco specifically objecting to five contested ballots, arguing that three of them represented stray votes.
COMELEC En Banc Ruling
The COMELEC En Banc, in a resolution dated January 18, 2005, affirmed the earlier ruling of the Second Division, stating that the votes for Layesa in Exhibits "9" and "13" were valid under the neighborhood rule, while reaffirming the decision regarding other challenged ballots. It denied reconsideration of the Second Division's findings.
Legal Issue
The legal question at hand is whether COMELEC properly credited Layesa with the votes cast on the disputed three ballots—Exhibits "9," "10," and "13."
Supreme Court Ruling
The Supreme Court partly granted the petition, determining that the vote cast for Layesa in Exhibit "10" is valid, whereas the votes in Exhibits "9" and "13" are classified as stray votes.
Application of Ballot Appreciation Rules
In assessing the contested ballots, the Court referenced the "neighborhood rule," derived from Section 211(19) of the Omnibus Election Code, which addresses votes for candidates inappropriately placed outside of designated areas on the ballot. According to this section, votes cast for a candidate who has not filed a candidacy or inappropriately marked ballots are considered stray and do not invalidate the entire ballot.
Evaluation of Exhibits
Exhibit "10": The Court ruled this ballot as valid due to the clarity of the voter’s intent shown through the use of the word "Charman" next to the respondent's name, suggesting the voter's intent to vote for Layesa for Punong Barangay.
Exhibits "9" and "13": The Court found these ballots as stray s
Case Syllabus (G.R. No. 166931)
The Case
- This case involves a petition for the writs of certiorari and prohibition aimed at nullifying the Resolution dated February 10, 2003, of the Commission on Elections (COMELEC) Second Division, as well as the Resolution dated January 18, 2005, of the COMELEC En Banc.
- The dispute centers around an election protest concerning the position of Punong Barangay (village chief) of Sta. Ana, San Pablo City.
The Facts
- Petitioner Ranilo A. Velasco and respondent Benigno C. Layesa, Jr. were candidates for the position of Punong Barangay during the barangay elections held on July 15, 2002.
- The election results proclaimed Velasco as the winner with 390 votes, while Layesa received 375 votes.
- Layesa contested the results, claiming that certain votes for him were improperly excluded and subsequently filed an election protest in the Municipal Trial Court in Cities, San Pablo City.
- The protest involved the revision of 26 ballots from four precincts, with Velasco initially seeking to dismiss the case but later filing a counterclaim for the revision of ballots from another precinct.
The Ruling of the Trial Court
- On August 23, 2002, the trial court issued a decision declaring a tie between Velasco and Layesa, with both candidates receiving 390 votes after revisions.
- The trial court ordered the drawing of lots to resolve the tie.
The Ruling of the COMELEC Second Division
- The COMELEC Second Division affirmed the trial court's decision on February 10, 2003, employing the "neighborhood rule" in its evaluation of certain ballots.
- Both parties filed motions for reconsideration, with Velasco focusing on five specific ballots, arguing they were either stray or marked.