Basmala v. Commission on Elections
REITERATIONFacts
The Antecedents: Petitioner Kennedy B. Basmala and private respondent Amenodin U. Sumagayan were candidates for mayor in Taraka, Lanao del Sur in the May 10, 2004 National and Local Elections. Sumagayan was initially declared winner with 2,103 votes against Basmala's 1,866 votes. Procedural History: Basmala filed an election protest with the Regional Trial Court (RTC) contesting the results in 21 precincts. The RTC, after tallying results from 38 precincts and rejecting returns from 5 precincts, declared Basmala the winner with 1,831 votes versus Sumagayan's 1,662 votes. The Petition: The Commission on Elections (COMELEC) Second Division reversed the RTC decision, upholding the election returns from the 5 contested precincts and declaring Sumagayan the winner with 2,103 votes. The COMELEC en banc affirmed this ruling. Basmala filed a petition for certiorari before the Supreme Court.
Issue(s)
Whether the petition for certiorari assailing the COMELEC resolutions is moot and academic. Whether the COMELEC committed grave abuse of discretion in reversing the RTC decision.
Ruling
The petition for certiorari is dismissed. The issue of who was the duly elected mayor is rendered moot and academic by the expiration of the contested office's term and the election of new officials. Furthermore, the Court found no grave abuse of discretion on the part of the COMELEC.
Ratio Decidendi
On the issue of mootness: The Court held that the issue of who won the mayoral election in Taraka, Lanao del Sur for the May 10, 2004 elections has become moot and academic because the term of the contested office has already expired, and new officials have been elected. Consequently, any judgment would have no practical legal effect. The Court emphasized that it is an exercise in futility to review records when the outcome cannot be practically applied. On the issue of grave abuse of discretion: The Court found no grave abuse of discretion on the part of the COMELEC that would warrant certiorari. Grave abuse of discretion implies a capricious exercise of judgment equivalent to a lack of jurisdiction. The COMELEC, as the specialized agency for election supervision, examined the records and evidence, and its findings of fact, when supported by substantial evidence, are considered final. The appreciation of election documents is a question of fact best left to the COMELEC, and the Supreme Court does not typically act as a trier of facts unless grave abuse of discretion is demonstrated.
Main Doctrine
A petition for certiorari seeking to annul COMELEC resolutions on election protests becomes moot and academic upon the expiration of the contested office's term and the election of new officials, and the Court will not delve into the merits if no grave abuse of discretion is shown.