Doruelo v. Commission on Elections
REITERATIONFacts
The Antecedents: Petitioner Esteban Doruelo and private respondent Tomas Baga, Jr. were among ten candidates for two seats in the Batasan Pambansa for North Cotabato in the May 14, 1984 elections. After the election returns were canvassed but before termination, Doruelo filed petitions for suspension of proclamation and nullification of election returns in Kabacan. A recheck of the canvass resulted in the official tally: Carlos B. Cajelo (75,067), Tomas D. Baga, Jr. (69,709), and Esteban D. Doruelo (64,162). Procedural History: Doruelo filed further petitions with the provincial board of canvassers for annulment of provincial canvass results. After these were dismissed, Doruelo appealed to the Commission on Elections (COMELEC) with various urgent petitions, including holding special elections, annulling election returns, and suspending proclamation. Carlos Cajelo and Tomas Baga, Jr. also filed petitions for their proclamation. These were docketed as Pre-Proclamation Case No. 66-84. The Petition: The COMELEC First Division set the case for hearing. After hearings and submission of memoranda, the COMELEC issued a Minute Resolution on June 14, 1984, dismissing the pre-proclamation controversy and proclaiming Tomas Baga, Jr. as the Second Assemblyman-elect. The resolution noted that the votes in the proposed special election areas were insufficient to alter the lead of Baga over Doruelo, and no prima facie evidence was submitted. An extended resolution was later issued on June 27, 1984, elaborating on the issues. Doruelo filed the instant petition for review on certiorari and prohibition, alleging grave abuse of discretion and denial of due process.
Issue(s)
Whether the COMELEC committed grave abuse of discretion amounting to lack of jurisdiction in issuing the Minute Resolution dated June 14, 1984. Whether the COMELEC denied petitioner due process in its proceedings. Whether the doctrine of statistical improbability was correctly applied or disregarded by the COMELEC.
Ruling
The petition is dismissed. The COMELEC did not commit grave abuse of discretion and observed due process. The dismissal of the pre-proclamation cases and the proclamation of Tomas D. Baga, Jr. are affirmed.
Ratio Decidendi
On the issue of grave abuse of discretion: The COMELEC did not commit grave abuse of discretion. The Minute Resolution correctly assessed that the proposed special elections in 22 voting centers, with a total of 5,994 voters, would not likely alter the election results, as Baga led Doruelo by 5,547 votes. It was deemed purely conjectural that Doruelo would win 100% or at least 90% of the votes in a special election. Furthermore, the COMELEC found no prima facie evidence to warrant the reception of evidence aliunde, which is a prerequisite for further proceedings in pre-proclamation cases. The subsequent extended resolution provided further detailed reasoning. On the issue of due process: The COMELEC duly observed the cardinal primary requirements of due process in administrative proceedings as laid down in Ang Tibay v. Court of Industrial Relations. Two hearings were conducted, and the petitioner was given the opportunity to cross-examine witnesses and present evidence. The parties also submitted memoranda. The COMELEC considered the evidence presented and based its decision on the records. The issues were clearly defined, and the reasons for the decision were articulated, with further details provided in the extended resolution. On the issue of statistical improbability: The COMELEC correctly disregarded the invocation of the doctrine of statistical improbability. The election returns from Pikit and Kabacan did not show a uniform tally favoring one party or a systematic blanking out of opposing candidates. Instead, votes were distributed among various candidates from different parties. The alleged high turnout in certain voting centers was between 90% to 92.22%, with a wide distribution of votes, which does not, by itself, justify the application of the statistical improbability rule, as held in Sinsuat v. Pendatun.
Main Doctrine
The Commission on Elections (COMELEC) did not commit grave abuse of discretion in dismissing pre-proclamation cases and proclaiming a winning candidate when the grounds for special elections were not sufficiently established, and no prima facie evidence was presented to warrant the reception of evidence aliunde. The COMELEC observed due process by providing hearings and considering the evidence presented.