Domingo v. Ramos
REITERATIONFacts
The Antecedents: In the mayoralty elections of Rosales, Pangasinan held on November 12, 1963, Fernando Ramos was proclaimed winner over Silvestre Domingo by eleven (11) votes. The official canvass showed Ramos with 2,632 votes and Domingo with 2,621 votes. Procedural History: Silvestre Domingo filed an election protest. The Court of First Instance of Pangasinan declared Domingo elected with 2,618 votes against Ramos's 2,603 votes. Fernando Ramos appealed to the Court of Appeals. The Court of Appeals reversed the trial court's decision, finding that Ramos obtained 2,630 votes and Domingo obtained 2,618 votes, thus winning by a plurality of 12 votes. Domingo appealed to the Supreme Court. The Petition: Domingo questioned the Court of Appeals' admission of certain ballots for Ramos and rejection of a ballot for Domingo. Specifically, he argued that 14 ballots admitted for Ramos, marked "A. Ramos," were stray votes for Aurora Ramos, an LP candidate for councilor, and that one ballot rejected for him (Exhibit R-67) should have been counted as idem sonans.
Issue(s)
Whether the Court of Appeals erred in admitting as valid votes for Fernando Ramos the fourteen (14) ballots marked as Exhibits D-5, D-24, D-28, D-43, D-45, D-54, D-55, D-92, D-94, D-98, D-156, D-159, D-199, and D-270, which were rejected by the trial court. Whether the Court of Appeals erred in rejecting the ballot marked as Exhibit R-67, which was admitted by the trial court as a valid vote for Silvestre Domingo. Whether the Court of Appeals erred in admitting as valid votes for Fernando Ramos the ballots marked as Exhibits D-30, D-68, D-91, D-160, D-198, D-212, and D-225. Whether Silvestre Domingo should have been declared the duly elected mayor.
Ruling
The Supreme Court reversed the decision of the Court of Appeals. It declared Silvestre Domingo as the duly elected mayor of Rosales, Pangasinan. The Court found that the 14 ballots marked "A. Ramos" for mayor should be considered stray votes and deducted from Fernando Ramos's total, resulting in Domingo having a plurality of two votes.
Ratio Decidendi
On the admission of 14 ballots for Fernando Ramos marked "A. Ramos": The Supreme Court held that these 14 ballots should be considered stray votes for mayor and deducted from Fernando Ramos's total. The Court applied the ruling in Calo v. Court of Appeals, which held that when a name is accompanied by initials, and those initials and surname belong to another candidate (even for a different office), the vote should be considered stray. The Court found the Court of Appeals' reasoning for distinguishing the Calo case unconvincing, particularly regarding the possibility of confusion between "A. Ramos" for mayor and "A. Ramos" for councilor, and the argument that "A" stood for "Ando." The Court emphasized that the law speaks of initials, not nicknames, and that the presence of "A." before "Ramos" in the context of another candidate named Aurora Ramos for councilor created ambiguity that should be resolved against the candidate. The Court concluded that deducting these 14 votes from Ramos's tally of 2,630 would leave him with 2,616 votes, giving Domingo a plurality of two votes. On the rejection of ballot Exhibit R-67 for Silvestre Domingo: The Court deemed it unnecessary to rule on this assignment of error in light of the outcome of the first assignment of error, which already changed the plurality of votes. On the admission of 7 other ballots for Fernando Ramos: Similarly, the Court found it unnecessary to address these assignments of error as the primary issue regarding the 14 ballots was dispositive of the case. On the declaration of Silvestre Domingo as duly elected mayor: Based on the re-evaluation of the 14 ballots, the Supreme Court concluded that Silvestre Domingo obtained a plurality of two votes over Fernando Ramos, thus reversing the Court of Appeals and declaring Domingo the winner.
Main Doctrine
The Supreme Court reversed the Court of Appeals, holding that ballots marked "A. Ramos" for mayor should be considered stray votes for Fernando Ramos, applying the ruling in Calo v. Court of Appeals, thereby changing the election outcome.