Inguito v. Court of Appeals
REITERATIONFacts
The Antecedents: In the November 12, 1963 elections, Porferio Inguito and Alfredo Orquillas, Sr. were candidates for mayor. Inguito was initially proclaimed elected by a plurality of one vote (645-644). Procedural History: Orquillas filed an election protest, which the Court of First Instance (CFI) decided in favor of Orquillas by one vote (647-646). Inguito appealed to the Court of Appeals (CA), which affirmed the CFI decision, finding Orquillas won by four votes (647-643). Inguito's motion for reconsideration was denied. The Petition: Inguito appealed to the Supreme Court, seeking the rejection of thirteen ballots found valid for Orquillas by the CA, alleging they were marked ballots. These thirteen ballots, all from Precinct No. 5, each contained a single repetition of a candidate's surname on the same line.
Issue(s)
Whether thirteen ballots, each containing a single repetition of a candidate's surname on the same line and cast in the same precinct, are considered marked ballots. Whether the doctrine regarding marked ballots applies differently when multiple ballots from a single precinct exhibit a common marking pattern.
Ruling
The Supreme Court reversed the decision of the Court of Appeals. It declared Porferio Inguito as the winner by a plurality of nine votes (643 for Inguito to 634 for Orquillas).
Ratio Decidendi
On the issue of marked ballots: The Court distinguished the present case from prior rulings. While a single repetition of a candidate's name on a ballot, absent evidence of intent to identify, does not invalidate it, the present case involves thirteen ballots from the same precinct exhibiting the same common feature – the repetition of a candidate's surname on the same line. This pattern, occurring across multiple ballots within a single precinct, evidences a scheme designed to mark those ballots. The Court emphasized that the repetition occurring on the same line in all thirteen ballots could not be deemed unintentional or due to oversight, unlike situations where repetitions might occur on different lines or in isolated instances. Therefore, these thirteen ballots were excluded as marked ballots. On the application of precedent: The Court applied the principle that a single repetition of a name does not invalidate a ballot in the absence of evidence of intent to identify, citing Katigbak v. Mendoza. However, it clarified that this rule pertains to isolated instances or ballots from different precincts. When, as in this case, thirteen ballots from the same precinct share a common characteristic of repetition on the same line, it indicates a deliberate pattern to mark those ballots. The Court also referenced Gutierrez v. Aquino and Katigbak v. Mendoza regarding ballots marked more than twice, but distinguished the present situation by focusing on the patterned repetition within a single precinct. The Court found that the common feature across these thirteen ballots demonstrated a deliberate intent to mark them, thus invalidating them for Orquillas. Consequently, Orquillas' vote count was reduced by thirteen, leading to Inguito's victory.
Main Doctrine
A pattern of repeating a candidate's surname on the same line in multiple ballots from the same precinct, even if only repeated once per ballot, evidences a scheme to mark said ballots, thereby invalidating them. However, a single repetition of a candidate's name on a ballot, absent evidence of intent to identify, does not invalidate the ballot, especially when the repetitions occur on different lines or are not part of a discernible pattern across multiple ballots from the same precinct.