Suliguin v. Commission on Elections
REITERATIONFacts
The Antecedents: Petitioner Margarito Suliguin and respondent Ecelson Sumague were candidates for the Sangguniang Bayan of Nagcarlan, Laguna in the May 10, 2004 elections. Following the canvassing of votes, the Municipal Board of Canvassers (MBOC) proclaimed Suliguin as the 8th Sangguniang Bayan member, having recorded 6,605 votes for him and 6,647 for Sumague. However, it was later discovered that an error occurred in the Statement of Votes (SOV) for Precincts 1A to 19A, where Sumague was credited with 644 votes instead of the actual 844, resulting in a deficit of 200 votes. Procedural History: Following the discovery of the error, Sumague requested a recomputation of the votes. The MBOC convened, confirmed the discrepancy, and determined that Sumague should have received 6,647 votes, surpassing Suliguin's 6,605. Consequently, the MBOC filed a petition with the Commission on Elections (Comelec) to correct the entries in the SOV. The Comelec's First Division granted this petition on July 21, 2004, nullifying Suliguin's proclamation and ordering Sumague's proclamation. Suliguin moved for reconsideration, which was denied by the Comelec En Banc on November 18, 2004. The Petition: Petitioner Margarito Suliguin filed a Petition for Certiorari under Rule 65 of the Revised Rules of Court, seeking to reverse the Comelec's resolutions. He argues that the Comelec committed grave abuse of discretion. Suliguin contends that the MBOC's petition to correct the entries was filed out of time, violating Comelec rules, and that the MBOC acted with bias and was functus officio after the proclamation. He further argues that the Comelec's reliance on previous rulings was misplaced as the circumstances differed. The core of his argument is that procedural technicalities should have prevented the correction of the vote count and the subsequent nullification of his proclamation.
Issue(s)
Whether or not respondent Comelec erred in granting the petition of the Municipal Board of Canvassers (MBOC) to nullify petitioner's proclamation as the 8th member of the Sangguniang Bayan in Nagcarlan, Laguna.
Ruling
The petition is bereft of merit. The COMELEC did not commit grave abuse of discretion in annulling the proclamation of petitioner. The Resolutions of the Commission on Elections in SPC No. 04-209 dated July 21, 2004 and November 18, 2004 are AFFIRMED. The Status Quo Order issued by the Court dated January 11, 2005 is LIFTED.
Ratio Decidendi
On Issue 1: The Supreme Court held that the Commission on Elections (COMELEC) did not err in annulling petitioner Suliguin's proclamation, as it was based on an erroneous computation of votes. The Court reiterated that election laws and the COMELEC Rules of Procedure, specifically Sections 3 and 4 of Rule 1, are to be liberally construed to ensure the holding of free, orderly, honest, peaceful, and credible elections, and to achieve a just, expeditious, and inexpensive determination of election proceedings. Technicalities, such as the alleged late filing of the petition by the MBOC or the argument that the MBOC was functus officio after proclamation, should not be allowed to defeat the substantive right to correct a manifest error and ascertain the true will of the electorate. A manifest clerical error, defined as one visible to the eye or obvious from the papers, includes a mistake in the addition of votes, as explicitly stated in Section 32, subparagraph 5 of Comelec Resolution No. 6669. The Court emphasized, citing Bince, Jr. v. Commission on Elections, that a proclamation based on faulty tabulation is flawed and void ab initio, and thus, an erroneously proclaimed candidate's assumption of office cannot validate an invalid proclamation nor deprive the COMELEC of its power to declare such proclamation a nullity. The COMELEC, exercising immediate supervision and control over boards of canvassers, has the authority to initiate motu proprio steps to correct errors to ensure the true winner is declared.
Main Doctrine
The Commission on Elections (COMELEC) has the authority to correct manifest clerical errors in the Statement of Votes, even if the petition for correction is filed out of time, to ensure that the true will of the electorate is ascertained and to prevent the validation of a proclamation based on a faulty tabulation.