Cayetano v. Commission on Elections
REITERATIONFacts
1. The Antecedents: On April 25, 1998, the Commission on Elections (COMELEC) conducted a plebiscite in Taguig, Metro Manila, on the conversion of the municipality into a highly urbanized city as mandated by Republic Act No. 8487. The question posed was whether residents approved the conversion. On April 26, 1998, the Plebiscite Board of Canvassers (PBOC) initially declared that 'No' votes prevailed, without completing the canvass of all election returns. Upon COMELEC en banc order, the PBOC reconvened, completed the canvass, and still proclaimed that negative votes prevailed. 2. Procedural History: Private respondents, alleging fraud and irregularities, filed a petition with the COMELEC seeking annulment of the plebiscite results with a prayer for revision and recount of ballots, which the COMELEC treated as an election protest (EPC No. 98-102). Petitioner intervened and filed a motion to dismiss, arguing the COMELEC lacked jurisdiction over plebiscite conduct. The COMELEC Second Division granted the motion, dismissing for lack of jurisdiction. The COMELEC en banc affirmed this. Private respondents filed a petition for certiorari and mandamus with the Supreme Court (G.R. No. 155855), which reversed the COMELEC's resolution, holding that the controversy falls under COMELEC's jurisdiction to enforce and administer laws relative to plebiscites. The Court directed the COMELEC to reinstate and decide. Subsequently, the COMELEC Second Division ordered the revision/recount of ballots. Upon termination, the committees submitted reports. The COMELEC Second Division failed to render a decision due to a lack of required votes, and the case was elevated to the COMELEC en banc. On December 8, 2004, the COMELEC en banc issued a Resolution granting, declaring and confirming the ratification and approval of the conversion of Taguig into a highly urbanized city, citing 21,105 affirmative votes as the majority and highest votes. 3. The Petition: Petitioner Alan Peter S. Cayetano filed two petitions for certiorari. G.R. No. 166388 assails the COMELEC en banc Resolution of December 8, 2004, declaring the ratification and approval of Taguig's conversion into a city. G.R. No. 166652 questions the COMELEC en banc Order of January 28, 2005, declaring the December 8, 2004 Resolution final and executory, and its recording in the COMELEC's Book of Entry of Judgments. Petitioner contends that the COMELEC acted with grave abuse of discretion, alleging that the revision of plebiscite ballots was incomplete and attended by irregularities, fraud, and anomalies, thus the revision could not be relied upon to determine the electorate's will. He asserts that Taguig must become a city 'the right way,' by a fair count of votes.
Issue(s)
Whether the COMELEC committed grave abuse of discretion amounting to lack or excess of jurisdiction in declaring the ratification and approval of the conversion of Taguig into a highly urbanized city. Whether the COMELEC had jurisdiction over the petition seeking annulment of the plebiscite results. Whether the revision of plebiscite ballots was incomplete and attended by irregularities, fraud, and anomalies.
Ruling
The petitions are dismissed for lack of merit. The COMELEC did not gravely abuse its discretion in issuing the assailed Resolution and Order.
Ratio Decidendi
On Grave Abuse of Discretion and Ratification: Based on the review of the evidence and the established jurisdiction of the COMELEC, the Supreme Court concluded that the COMELEC did not commit grave abuse of discretion amounting to lack or excess of jurisdiction in issuing its Resolution of December 8, 2004, and its subsequent Order of January 28, 2005. The COMELEC's decision to declare and confirm the ratification and approval of the conversion of Taguig into a highly urbanized city was based on its findings from the revised and recounted ballots, which were deemed sufficient and credible by the Commission. On the COMELEC's Jurisdiction over Plebiscites: The Supreme Court reiterated its ruling in G.R. No. 155855, holding that the controversy on the conduct of the Taguig plebiscite is a matter involving the enforcement and administration of a law relative to a plebiscite. This falls squarely within the jurisdiction of the COMELEC under Section 2(1), Article IX(C) of the Constitution, which authorizes it to "enforce and administer all laws and regulations relative to the conduct of an election, plebiscite, initiative, referendum, and recall." Therefore, the COMELEC correctly exercised its jurisdiction in reinstating and deciding the petition concerning the plebiscite results. On the Alleged Incomplete Canvass and Irregularities and the COMELEC's Factual Findings: The Court emphasized that the matters raised by the petitioner concerning the alleged incomplete canvass of plebiscite votes during the revision proceedings and the purported irregularities, frauds, and anomalies committed therein are factual in nature. These issues involve an examination of the admissibility and sufficiency of evidence presented during the revision proceedings before the COMELEC. Such factual determinations are generally beyond the scope of a special civil action for certiorari under Rule 65 of the Rules of Civil Procedure, which is confined to resolving issues mainly involving jurisdiction, including grave abuse of discretion amounting to lack or in excess of jurisdiction. Despite the procedural limitations, the Court reviewed the evidence and found that petitioner's allegation of an incomplete revision was erroneous. The COMELEC considered not only the total votes from the PBOC Canvassing Report but also the physical count of ballots, returns from uncontested precincts, and appreciation of contested ballots. The COMELEC's final tally showed 21,105 affirmative votes and 19,460 negative votes. These factual findings of the COMELEC, supported by evidence, are accorded not only respect but finality. The Court affirmed that the conduct of plebiscites and the determination of their results are the exclusive business of the COMELEC, which possesses indisputable expertise in election and related laws. Consequently, the COMELEC's acts enjoy the presumption of regularity in the performance of official duties.
Main Doctrine
The Commission on Elections (COMELEC) has jurisdiction over matters involving the enforcement and administration of laws relative to the conduct of plebiscites, and its factual findings, when supported by evidence, are accorded finality. Petitions for certiorari challenging COMELEC resolutions are confined to issues of jurisdiction, including grave abuse of discretion.