Alcala v. Commission on Elections
REITERATIONFacts
The Antecedents: Petitioners and private respondents were nominees for Vice-Mayor and members of the Sangguniang Panglungsod in Lucena City, both claiming to be the official candidates of the Kilusang Bagong Lipunan (KBL). On January 2 and 4, 1980, both respondent Mario L. Tagarao and Governor Anacleto C. Alcala submitted their respective lists of candidates to the Commission on Elections (COMELEC). The COMELEC attempted to verify which list was official but was unsuccessful. Procedural History: On January 19, 1980, the COMELEC issued a resolution recognizing Mario L. Tagarao's nominees as the official KBL candidates. This resolution was publicized, and on election day, January 30, 1980, the certified list of candidates posted at voting centers listed petitioners as independent candidates and respondents as official KBL candidates. The election proceeded, and respondents were elected and proclaimed. The Petition: Petitioners claimed that their nomination was duly authorized by the KBL leadership and that the COMELEC committed grave abuse of discretion in listing them as independent candidates. They prayed for the votes cast for respondents to be credited to them and for them to be declared winners.
Issue(s)
Whether the Commission on Elections committed grave abuse of discretion in declaring private respondents as the official candidates of the KBL. Whether the results of the election should be annulled or disregarded due to the alleged error of the COMELEC in the list of candidates.
Ruling
The petition is dismissed. The resolution of the Commission on Elections is sustained.
Ratio Decidendi
On the issue of grave abuse of discretion: The Court held that the COMELEC did not commit grave abuse of discretion. It noted that the electorate of Lucena City was aware of the two competing groups of candidates, both using the KBL banner, and had the opportunity to choose. The COMELEC's resolution of January 19, 1980, dispelled any remaining doubt, and on election day, the certified list clearly distinguished between independent and official KBL candidates. The Court found no arbitrariness in the COMELEC's decision, as respondent Tagarao, as the City Mayor, was duly authorized to nominate KBL candidates for Lucena City, and the COMELEC's action was not repudiated by the KBL leadership. On the issue of the validity of the election results: The Court emphasized that the election returns showed a clear manifestation of the people's will, with respondent Tagarao winning by a significant margin, and even independent candidates receiving more votes than some KBL candidates. Therefore, disregarding the election results would be contrary to the principle of upholding the people's choice. The Court also cited the principle that election rules and regulations are mandatory before voting but become directory after the election, especially when the voters had full opportunity to make their choice.
Main Doctrine
Rules and regulations for the conduct of elections, while mandatory before the voting, become directory after the election is held, especially when the electorate had full opportunity to decide for whom to vote.