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PETRONILA S. RULLODA v. COMELEC

FACTS:

In the barangay elections of July 15, 2002, Romeo N. Rulloda and Remegio L. Placido were contending candidates for Barangay Chairman of Sto. Tomas, San Jacinto, Pangasinan. Romeo passed away on June 22, 2002 due to a heart attack. His widow, petitioner Petronila Rulloda, sought permission from the Commission on Elections (COMELEC) to run as a candidate for Barangay Chairman in place of her late husband. Petitioner garnered 516 votes, while respondent Placido received 290 votes. Despite petitioner's higher vote count, the Board of Canvassers proclaimed Placido as the Barangay Chairman of Sto. Tomas. Petitioner later discovered that the COMELEC had issued a resolution denying due course to her certificate of candidacy and proclaiming respondent Placido as the winner. Petitioner filed a petition for certiorari seeking to annul the COMELEC's resolutions, nullify respondent's proclamation, and proclaim herself as the duly elected Barangay Chairman.

ISSUES:

  1. Whether or not substitution of candidates is allowed in barangay elections.

  2. Whether or not the petitioner's letter-request can be treated as a certificate of candidacy.

  3. Whether or not the petitioner obtained the plurality of votes in the contested election.

RULING:

  1. Yes, substitution of candidates is allowed in barangay elections. The absence of a specific provision governing substitution of candidates in barangay elections does not imply a prohibition against said substitution. Laws governing election contests must be liberally construed to ensure that the will of the people in the choice of public officials is not hindered by technical objections.

  2. Yes, the petitioner's letter-request can be treated as a certificate of candidacy. The Commission on Elections (COMELEC) treated the petitioner's letter-request to be allowed to run as Barangay Chairman as a certificate of candidacy. Technicalities and procedural niceties should not stand in the way of the true will of the electorate.

  3. Yes, the petitioner obtained the plurality of votes in the contested election. The petitioner garnered 516 votes while the respondent got only 290 votes. Technicalities and procedural barriers must yield if they obstruct the determination of the true will of the electorate.

PRINCIPLES:

  • An election is the embodiment of the popular will, and the winner is the candidate who has obtained a majority or plurality of valid votes cast. Public elective offices should be filled by those who receive the highest number of votes cast.

  • Political laws must be construed to give effect to, rather than frustrate, the will of the voters. In case of doubt, political laws must be construed to give life and spirit to the popular mandate freely expressed through the ballot.

  • Technicalities and procedural barriers should not hinder the true will of the electorate in the choice of their elective officials. Laws governing election contests must be liberally construed to ensure the free and intelligent casting of votes and the correct ascertainment of results.