Aradais v. Commission on Elections
REITERATIONFacts
The Antecedents: Petitioner Hadja Nida B. Aradais and respondent Abdusali Asmadun were mayoralty candidates in Lugus, Sulu in the May 14, 2001 elections. After the casting of votes, ballot boxes were brought to the 104th Army Brigade headquarters for centralized counting and canvassing. The canvassing was completed on May 17, 2001. Two Certificates of Canvass (COC) with the same serial number emerged: one proclaiming respondent Asmadun as mayor-elect, signed by the Chairman and Secretary of the Municipal Board of Canvassers (BOC), but not the Vice-Chairman; and another proclaiming petitioner Aradais as mayor-elect, signed by all three members of the BOC. Procedural History: Respondent Asmadun took his oath of office on May 19, 2001, and assumed office on July 2, 2001. Petitioner Aradais took her oath on June 23, 2001. On June 26, 2001, the COMELEC Regional Director advised that only respondent's proclamation was recognized. Petitioner then filed a petition for annulment of respondent's proclamation with the COMELEC. The COMELEC created an ad hoc committee to investigate. The committee held a clarificatory hearing where BOC Chairman Bakri testified that the first COC (proclaiming respondent) was legitimate and he was forced to sign the second COC. BOC Secretary Dammang testified she only signed the first COC and that BOC member Uddoh left the proceedings due to stomach ache. The Ad Hoc Committee recommended affirming respondent's proclamation and nullifying petitioner's proclamation as spurious. The COMELEC Second Division affirmed this recommendation. Petitioner's Motion for Reconsideration was denied by the COMELEC En Banc. The Petition: Petitioner filed a Petition for Certiorari, arguing that the COMELEC En Banc gravely abused its power by delegating its constitutional duty to a mere ad hoc committee and should have ordered a recanvass and retabulation instead of relying on the committee's findings.
Issue(s)
Whether the COMELEC En Banc committed grave abuse of discretion in delegating its constitutional duty to an ad hoc committee. Whether the COMELEC should have ordered a recanvass and retabulation of votes instead of relying on the ad hoc committee's findings.
Ruling
The petition is dismissed for lack of merit. The COMELEC En Banc did not commit grave abuse of discretion amounting to lack or excess of jurisdiction.
Ratio Decidendi
On the delegation of duty to the ad hoc committee: The Court held that the findings and recommendations of the ad hoc committee were merely advisory in nature and did not bind the COMELEC. The COMELEC is presumed to have reviewed the records and made its own assessment, absent any evidence to the contrary. The Court emphasized that the COMELEC has broad powers to ascertain election results through any available means it deems effective. Requiring parties to submit position papers, memoranda, and conducting clarificatory hearings were within the COMELEC's discretion. The Court reiterated that its power to review COMELEC judgments is limited to instances of grave abuse of discretion, which was not demonstrated by the petitioner. The resolution assailed was supported by substantial evidence and was not whimsical, capricious, or arbitrary. On the necessity of recanvass and retabulation: The Court found that the COMELEC's chosen method of investigation, which included the ad hoc committee's report and clarificatory hearings, was a valid exercise of its broad powers to ascertain election results. The petitioner failed to present evidence that the COMELEC merely relied on the ad hoc committee's findings without conducting its own assessment. Therefore, the COMELEC's decision to affirm the proclamation of respondent Asmadun based on the evidence presented and its own review was within its discretionary powers. The Court found no grave abuse of discretion in the COMELEC's not ordering a recanvass and retabulation, as the existing process was deemed sufficient to ascertain the true results in this instance.
Main Doctrine
The Commission on Elections (COMELEC) has broad powers to ascertain the true results of an election by available means, and its discretion to avail of effective means, such as requiring position papers, memoranda, and conducting clarificatory hearings, is within its authority. The findings of an ad hoc committee are merely advisory and do not bind the COMELEC, which must make its own assessment of the records. The COMELEC's judgment cannot be overturned unless clearly tainted with grave abuse of discretion.