Fajura v. Veloso
REITERATIONFacts
The Antecedents: Petitioner Jose Fajura and respondent Edmundo Flores were candidates for barrio captain. Flores was declared the winner with 103 votes against Fajura's 56. Procedural History: Petitioner filed an election protest, alleging illegal transfer of the election site, prevention of his sympathizers from voting due to the presence of the mayor and police, and fraud including the tearing up of the voters' list. The municipal court dismissed the protest, holding that a withdrawal of endorsement by one of the five registered voters who filed Fajura's certificate of candidacy nullified Fajura's candidacy, rendering votes cast for him as stray votes. The Court of First Instance affirmed this dismissal. The Petition: Petitioner sought certiorari from the Supreme Court, arguing that the unilateral withdrawal of one endorser should not nullify his candidacy and his right to contest the election results.
Issue(s)
Whether the unilateral withdrawal of one of the five registered voters who filed petitioner's certificate of candidacy could nullify his candidacy and divest him of legal standing to contest the election results. Whether the election of respondent Flores was valid.
Ruling
The Supreme Court set aside the order of dismissal and remanded the case to the municipal court for further proceedings on the merits. The Court held that the withdrawal of one endorser did not nullify the certificate of candidacy and that petitioner retained legal standing to pursue his protest.
Ratio Decidendi
On the issue of the withdrawal of endorsement: The Court held in the negative. A certificate of candidacy filed on behalf of a candidate by five registered voters, in accordance with the Revised Barrio Charter and accepted by the candidate, cannot be unilaterally nullified by the withdrawal of one of the endorsers without the candidate's express consent. This is especially true when the candidate has acted on the candidacy, was voted for, and has a vested interest in pursuing the election results. The Court emphasized that such a withdrawal, particularly when it appears to have been obtained by trickery and bad faith as indicated by the repudiated affidavit of the endorser, should not be recognized to divest the candidate of his standing to contest the election. The Court cited previous rulings that support the principle that a candidate's standing, once established, cannot be easily undermined by unilateral actions of third parties without the candidate's consent. The public interest in the integrity of elections also weighs against allowing such facile nullification of candidacies. On the issue of the election of respondent Flores: The Court did not rule on the merits of the alleged fraud or irregularities in the election itself, as the lower courts dismissed the case on a procedural technicality (the validity of the certificate of candidacy). By remanding the case, the Supreme Court allows for a full trial on the merits to determine the validity of the election and the proclamation of respondent Flores.
Main Doctrine
A certificate of candidacy filed on behalf of a candidate by registered voters, once accepted and acted upon by the candidate, cannot be unilaterally nullified by the withdrawal of one of the endorsers without the candidate's consent, especially when the withdrawal is questionable and repudiated, and the candidate has a vested interest in pursuing the election results.