Digman v. Commission on Elections
REITERATIONFacts
The Antecedents: Cecil Digman, the Nacionalista candidate for vice-mayor of La Trinidad, Benguet, was the subject of a petition for disqualification filed by his opponent, Marcelo U. Aguindadao (KILUSANG BAGONG LIPUNAN candidate), on the ground of turncoatism. Evidence presented showed that Digman had affiliated with the KBL on December 26, 1979, attended a KBL caucus, was treasurer of the municipal KBL committee, lost in the KBL convention, and subsequently proclaimed himself as the NP candidate. Procedural History: Digman did not present any evidence. The COMELEC, via telegram on January 31, 1980, directed the municipal board of canvassers to withhold Digman's proclamation, but the board disregarded this and proclaimed Digman as the elected vice-mayor on February 5, 1980. Digman obtained 6,820 votes against Aguindadao's 3,811. The COMELEC, in a resolution dated August 27, 1980, disqualified Digman and declared his votes as stray. In an order dated December 16, 1980, the COMELEC denied Digman's motion for reconsideration, constituted itself as the Board of Canvassers, and proclaimed Aguindadao as the duly elected vice-mayor. The Petition: Digman assailed the COMELEC's resolution and order through a petition for certiorari filed on January 26, 1981, arguing it was a continuation of a pre-proclamation controversy.
Issue(s)
Whether the Supreme Court should disturb the COMELEC's factual finding of turncoatism against petitioner Cecil Digman. Whether the COMELEC had the jurisdiction to proclaim the winning candidate in a pre-proclamation controversy, especially after the proclamation of the petitioner by the municipal board of canvassers.
Ruling
The petition for certiorari filed by Cecil Digman was dismissed. The Supreme Court affirmed the COMELEC's resolution and order, upholding the disqualification of Digman on the ground of turncoatism and proclaiming Marcelo U. Aguindadao as the duly elected vice-mayor of La Trinidad.
Ratio Decidendi
On the issue of disturbing COMELEC's factual finding of turncoatism: The Court held that it should not disturb the COMELEC's factual finding that Digman changed his party affiliation from KBL to NP within six months preceding the election. This finding was supported by evidence presented by Aguindadao, including Digman's affiliation with the KBL, attendance at its caucus, and his position as treasurer of the municipal KBL committee. The Court cited numerous cases where it has consistently upheld COMELEC's factual findings in election cases, particularly in pre-proclamation controversies. The fact that Digman did not present any evidence to refute the allegations further strengthened the COMELEC's conclusion. Therefore, Digman was disqualified to run under the NP banner, and his opponent should be proclaimed in his stead, as per established election laws and jurisprudence. On the COMELEC's jurisdiction to proclaim the winning candidate: The Court distinguished the present case from Venezuela vs. Commission on Elections, where a petition to disqualify was filed after the proclamation. In this case, the COMELEC had directed the municipal board of canvassers to withhold proclamation, but the board disregarded the directive and proclaimed Digman. The COMELEC, in resolving the disqualification case, acted to correct this irregularity and, in effect, constituted itself as the Board of Canvassers to ensure the proper proclamation of the qualified candidate. The Court found this action appropriate in the context of a pre-proclamation controversy where the initial proclamation was made in defiance of COMELEC's directive. The Court reiterated that the issue of turncoatism was a pre-proclamation matter that COMELEC had the authority to resolve before proclamation, and its subsequent order to proclaim Aguindadao was a necessary consequence of Digman's disqualification.
Main Doctrine
The Supreme Court affirmed the Commission on Elections' (COMELEC) factual finding that petitioner Cecil Digman committed turncoatism, disqualifying him from running as vice-mayor. The Court held that it should not disturb COMELEC's factual findings in pre-proclamation controversies, especially when supported by evidence, and that the proper remedy for the respondent, Marcelo U. Aguindadao, was to be proclaimed as the duly elected vice-mayor.