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ARIEL G. DE GUZMAN v. COMELEC

FACTS:

The case involves an election dispute between Ariel De Guzman and Nestor Pulido for the position of Provincial Board Member in the First District of Pangasinan. De Guzman filed an election protest alleging errors in tabulation in the election returns and statements of votes by precinct. Pulido, who was initially proclaimed as the winner, filed a counter-protest.

De Guzman also filed letter-petitions with the COMELEC Special Provincial Board of Canvassers (SPC) seeking correction of tabulation errors. However, the COMELEC en banc dismissed these letter-petitions, stating that the election protest case would adequately address the parties' allegations and evidence.

The COMELEC First Division issued a Resolution annulling De Guzman's proclamation and declaring Pulido as the duly elected Provincial Board Member. De Guzman sought reconsideration, arguing that the base figures used by the First Division were incorrect and that the tabulation errors should have been rectified before determining the final vote count. He also claimed that certain ballots were misappreciated in favor of Pulido.

The COMELEC en banc denied De Guzman's motion for reconsideration, stating that it was now their responsibility to settle the matter since the First Division did not address the issues raised. They found that De Guzman's evidence consisting of photocopies of election returns and statements of votes had no probative value. They also noted that De Guzman failed to present competent evidence and did not submit original election returns to support his claims of errors in addition. The COMELEC en banc affirmed Pulido's victory with a 73-vote margin.

De Guzman subsequently filed a petition for certiorari with the Supreme Court.

ISSUES:

  1. Whether the COMELEC en banc gravely abused its discretion in failing to correct the manifest errors of tabulation and wrong base figures used in the computation of the final votes.

  2. Whether the COMELEC en banc erred in sustaining the First Division's appreciation findings without rectifying or reversing the invalidation of certain ballots.

  3. Whether the COMELEC en banc acted arbitrarily and capriciously in upholding the factual findings of the First Division, disregarding manifest errors in tabulation.

  4. Whether De Guzman presented sufficient evidence to support his allegations.

RULING:

  1. The COMELEC en banc did not gravely abuse its discretion in failing to correct the errors of tabulation and base figures. The First Division already examined the ballots and ruled upon their validity, finding that Nestor Pulido won over Ariel De Guzman with a margin of 73 votes. The COMELEC en banc must accord great weight to the findings of the First Division unless there is a substantial showing of an erroneous estimation of the evidence presented.

  2. The COMELEC en banc did not commit grave abuse of discretion in sustaining the appreciation findings of the First Division. The appreciation of contested ballots and election documents is a question of fact best left to the determination of the COMELEC.

  3. The Court finds that the COMELEC en banc acted whimsically, capriciously, and without any rational basis in upholding the factual findings of the First Division. It failed to properly resolve the Motion for Reconsideration before it and neglected to scrutinize the evidence presented. The COMELEC should have considered the formally offered certified true copies of the Election Returns and Statement of Votes by Precinct, as well as its own Minutes of the Proceedings in the Revision and the Revision Reports of the contested precincts which confirmed the manifest errors in vote counting. Therefore, the COMELEC's ruling is reversed.

PRINCIPLES:

  • The COMELEC must consider the documents formally offered in evidence in accordance with the rules of court.

  • The findings of the First Division of the COMELEC must be accorded great weight unless there is a substantial showing that it was made from an erroneous estimation of the evidence presented.

  • The COMELEC's appreciation of ballots and election documents is subject to a presumption of regularity.

  • Factual findings of administrative agencies are not infallible and can be set aside when they fail the test of arbitrariness, or upon proof of gross abuse of discretion, fraud, or error of law.

  • Decisions of administrative agencies are generally accorded great respect and finality by the courts due to their special knowledge and expertise in matters falling under their jurisdiction.

  • Administrative bodies can be subject to judicial review if there is grave abuse of discretion, jurisdictional infirmity, or error of law.

  • In election contests where the correctness of the number of votes is involved, the best and most conclusive evidence are the ballots themselves or, when the ballots are not available, the election returns.

  • The cardinal objective of ballot appreciation is to discover and give effect to the intention of the voters.

  • Every ballot shall be presumed valid unless clear and good reasons justify its rejection.

  • Extreme caution should be observed before any ballot is invalidated, and doubts in the appreciation of ballots are resolved in favor of their validity.

  • Laws and statutes governing election contests, especially the appreciation of ballots, must be liberally construed to ensure that the will of the electorate is not defeated by technical infirmities.