Case Summary (G.R. No. 129096)
Facts of the Case
In the 1996 Sangguniang Kabataan elections, Julian Lallave, Jr. won against Marivic Zarate with a narrow margin of one vote, receiving 46 votes compared to Zarate's 45. The election results were proclaimed by the Barangay Board of Canvassers. Zarate subsequently initiated an election protest, claiming that at least three votes, marked “JL,” attributed to Lallave should have been invalidated as they purportedly did not correctly identify a candidate, given there was no candidate with the initials "JL."
Municipal Trial Court Decision
On September 9, 1996, the Municipal Trial Court annulled Lallave’s proclamation, designating Zarate as the winner after determining that some ballots were marked and therefore invalid. The Court concluded with Zarate having 44 valid votes against Lallave's reduced count of 38 following the invalidation of marked ballots.
Appeals to the Commission on Elections
Dissatisfied with the Municipal Trial Court's ruling, Lallave appealed to the COMELEC, arguing that the ballots marked with "JL" were valid, citing that he was the only candidate with those initials. Zarate countered, emphasizing that the trial court's ruling was correct in invalidating those contested votes.
COMELEC Resolution
On April 24, 1997, the COMELEC En Banc overturned the trial court’s decision and reinstated Lallave as the SK Chairman, declaring that the votes marked with "JL" should be counted. The COMELEC reasoned that the initials sufficiently identified Lallave as the intended candidate according to Section 211, par. 14 of the Omnibus Election Code.
Supreme Court Intervention
Following the unfavorable COMELEC decision, Zarate sought relief from the Supreme Court, arguing that the COMELEC acted with grave abuse of discretion. The issues for resolution included the validity of the "JL" marked ballots and the jurisdictional accuracy of the COMELEC’s procedure in hearing the appeal.
Jurisdictional Concerns
The Supreme Court identified a significant jurisdictional issue regarding the COMELEC's En Banc handling of the appeal from the Municipal Trial Court. The 1987 Constitution and the corresponding rul
...continue readingCase Syllabus (G.R. No. 129096)
Background of the Case
- The case involves a petition for certiorari filed by Marivic Zarate against the Commission on Elections (COMELEC) and Julian Lallave, Jr.
- The petition alleges grave abuse of discretion by the COMELEC in its Resolution dated April 24, 1997, which annulled the decision of the Municipal Trial Court of Malasiqui, Pangasinan.
- The Municipal Trial Court had declared Julian Lallave, Jr. as the duly elected Sangguniang Kabataan (SK) Chairman of Barangay Ican, Malasiqui, Pangasinan.
Election Context
- During the 1996 Sangguniang Kabataan elections, Julian Lallave, Jr. won over Marivic Zarate by a narrow margin of one vote, with Lallave receiving 46 votes and Zarate 45 votes.
- The Barangay Board of Canvassers proclaimed Lallave as the SK Chairman based on these results.
Election Protest
- Marivic Zarate filed an election protest on May 16, 1996, alleging that the Board of Election Tellers improperly counted votes marked "JL" in favor of Lallave, which she claimed were invalid.
- Zarate's argument was based on the assertion that the initials "JL" did not correspond to any official name of the candidates, rendering those votes irregular and void.
Municipal Trial Court Decision
- On September 9, 1996, the Municipal Trial Court ruled in favor of Zarate, invalidating eight of Lallave's ballots and one of Zarate'