The Supreme Court’s decision in Milla v. Balmores-Laxa clarifies the procedural requirements for the Commission on Elections (COMELEC) when resolving pre-proclamation disputes. The Court ruled that COMELEC must initially delegate the hearing and resolution of such cases to a division before the matter can be elevated to the En Banc, emphasizing adherence to constitutional mandates. This ensures a structured review process in election-related controversies and upholds the rights of candidates involved.

From Ballot Box to Bench: Did COMELEC Jump the Gun?

In the May 14, 2001 elections, Manuel Milla and Regina Balmores-Laxa competed for a council seat in Gerona, Tarlac. After the Municipal Board of Canvassers (BOC) proclaimed Milla as the eighth winning candidate on May 18, 2001, Balmores-Laxa filed a petition with the COMELEC a month later, alleging discrepancies in the Statement of Votes. Specifically, she claimed that the entries for four precincts didn’t match the corresponding election returns, asserting that Milla’s votes had been unlawfully inflated.

Balmores-Laxa supported her claims with photocopies of election returns and certified true copies of the Statement of Votes. The alleged discrepancy totaled 350 votes, a significant number considering Milla led Balmores-Laxa by only 46 votes according to the Certificate of Canvass. In response, Milla, who had already taken his oath and assumed office, sought the petition’s dismissal. He argued it was filed beyond the prescribed period, and pre-proclamation cases should end upon proclamation and assumption of office. Milla further contended that alleged padding of the statement of votes was an improper subject for a pre-proclamation case. The BOC admitted errors existed and asked to reconvene to fix them, even as they denied malicious intent.

The COMELEC En Banc sided with Balmores-Laxa, finding Milla’s votes had been improperly padded. It nullified Milla’s proclamation and declared Balmores-Laxa the rightful councilor, prompting Milla to seek recourse with the Supreme Court. Milla argued the COMELEC lacked jurisdiction because the petition was filed past the five-day reglementary period and that his assumption of office had already terminated the case. He also argued the COMELEC acted outside its jurisdiction when it acted on a case over municipal officials at the En Banc level. The Supreme Court focused on the procedural aspect of how the COMELEC handled the case, specifically addressing its jurisdiction and process in line with the constitution.

The Supreme Court addressed whether COMELEC properly exercised its power. The court recognized COMELEC could suspend its own procedural rules to promote fairness and accuracy in elections. Even so, the Court turned its attention on Sec. 3 of Art. IX-C of the 1987 Constitution, regarding pre-proclamation controversies, which says:

Sec. 3. The Commission on Elections may sit en banc or in two divisions, and shall promulgate its rules of procedure in order to expedite disposition of election cases, including pre-proclamation controversies. All such election cases shall be heard and decided in division, provided that motions for reconsideration of decisions shall be decided by the Commission en banc.

It emphasized that cases like Balmores-Laxa’s, involving a pre-proclamation controversy, should initially be heard and decided by a COMELEC division before reaching the En Banc. Since the COMELEC En Banc acted directly on Balmores-Laxa’s petition without prior review by a division, it acted without jurisdiction. As a result, the Supreme Court declared the COMELEC’s Resolution dated December 18, 2001, null and void. It instructed the COMELEC to assign SPC No. 01-311 to a division for proper resolution.

FAQs

What was the key issue in this case?	The main issue was whether the COMELEC properly exercised its jurisdiction when it directly handled a pre-proclamation controversy without prior review by a division.
What is a pre-proclamation controversy?	A pre-proclamation controversy is a dispute concerning the election returns and qualifications of candidates that arises before the official proclamation of election results. These usually involve errors in the statement of votes and questions of alleged fraud.
Why did the Supreme Court rule against the COMELEC in this case?	The Supreme Court ruled against the COMELEC because the case bypassed the required initial review by a division, violating Section 3, Article IX-C of the 1987 Constitution, and procedural process in election dispute resolutions.
What does Section 3, Article IX-C of the Constitution say?	Section 3, Article IX-C states that pre-proclamation controversies should first be heard and decided by a division of the COMELEC, with motions for reconsideration handled by the En Banc. This ensures the matter is examined at two separate levels within the COMELEC.
What was the specific allegation made by Balmores-Laxa?	Balmores-Laxa alleged that the entries for four precincts in the Statement of Votes did not correspond to the election returns for those precincts, resulting in inflated votes for Milla. She asserted Milla got 350 improper votes.
What did the Supreme Court order the COMELEC to do?	The Supreme Court ordered the COMELEC to set aside its resolution and assign the case to a division, directing the division to resolve the case with reasonable dispatch, respecting constitutional provisions.
What was the basis of Milla’s argument against the COMELEC’s jurisdiction?	Milla argued that the petition was filed beyond the reglementary period and that his assumption of office terminated the pre-proclamation case, challenging COMELEC’s assumption of the case after he was seated.
Was there evidence of vote padding in this case?	The COMELEC En Banc found that there was vote padding favoring Milla; however, the Supreme Court did not rule on the factual evidence of vote padding, focusing instead on the procedural error.

This case highlights the importance of following procedural rules in resolving election disputes. The Supreme Court emphasized that COMELEC must adhere to constitutional and procedural requirements, reinforcing a systematic and structured review process to maintain the integrity and fairness of electoral proceedings.

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Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Milla v. Balmores-Laxa, G.R. No. 151216, July 18, 2003