The Supreme Court affirmed the Commission on Elections’ (COMELEC) authority to correct manifest errors in election results, even if it means suspending procedural rules. This decision underscores the importance of ensuring the accurate tabulation of votes to reflect the true will of the electorate. It allows COMELEC to rectify clerical errors in vote counting without being strictly bound by procedural technicalities, emphasizing substance over form in safeguarding the integrity of electoral processes. This ruling validates COMELEC’s exercise of its administrative powers to address clear and demonstrable errors that could otherwise distort election outcomes.

Correcting the Count: How Sta. Cruz Sangguniang Bayan Seat Was Contested

The case arose from the 2001 Sangguniang Bayan elections in Sta. Cruz, Ilocos Sur, where a discrepancy was discovered in the tally of votes for Alberto Jaramilla. Antonio Suyat, another candidate, noticed that Jaramilla was incorrectly credited with 73 votes in Precinct No. 34A1 instead of the actual 23 votes reflected in the Election Return. Suyat promptly filed a petition with the COMELEC to correct what he claimed was a manifest error. The COMELEC en banc granted the petition, annulled Jaramilla’s proclamation, and directed a new Municipal Board of Canvassers to correct the entry and proclaim Suyat as the eighth member of the Sangguniang Bayan. Jaramilla then sought recourse from the Supreme Court, questioning the COMELEC’s jurisdiction and its decision to overlook procedural lapses in Suyat’s petition.

The Supreme Court addressed the issue of COMELEC’s jurisdiction, clarifying the instances when the commission can act en banc. The Court cited Article IX-C, Section 3 of the Constitution, which provides that election cases, including pre-proclamation controversies, should be heard and decided by a division of the COMELEC, with motions for reconsideration decided by the commission en banc. However, this applies only when the COMELEC exercises its adjudicatory or quasi-judicial powers.

The Court emphasized that when the COMELEC exercises its administrative functions, such as correcting a manifest mistake in the addition of votes, the en banc can directly act on it. This doctrine, established in Castromayor v. COMELEC, distinguishes between the COMELEC’s quasi-judicial role and its administrative function to ensure fair and accurate elections. In this case, the alleged error was a simple clerical mistake in transcribing votes from the election return to the Statement of Votes by Precinct, requiring only a clerical correction without the need to open ballot boxes or examine ballots. Therefore, the COMELEC en banc properly assumed original jurisdiction over the petition.

Building on this principle, the Court tackled Jaramilla’s arguments regarding the procedural defects in Suyat’s petition. Jaramilla argued that Suyat’s petition should have been dismissed because it was filed beyond the 5-day reglementary period and lacked a certification against forum-shopping. However, the Court invoked Section 4, Rule 1 of the COMELEC Rules, which allows the COMELEC to suspend its rules in the interest of justice. This provision grants the COMELEC the discretion to relax procedural requirements to ensure the speedy resolution of cases and to prevent technicalities from obstructing the pursuit of justice.

SEC. 4. Suspension of the Rules – In the interest of justice and in order to obtain speedy disposition of all matters pending before the commission, these rules or any portion thereof may be suspended by the Commission.

Further, the Court addressed Jaramilla’s claim that Suyat failed to pay the prescribed filing fees. The Court referred to Section 18, Rule 40 of the COMELEC Rules of Procedure, which states:

SEC 18. Nonpayment of Prescribed Fees – If the fees above prescribed are not paid, the Commission may refuse to take action thereon until they are paid and may dismiss the action or the proceeding.

The Court emphasized that the use of the word “may” in the provision indicates that the COMELEC has the discretion to either entertain the petition or not in case of non-payment of legal fees. This discretion reinforces the COMELEC’s authority to prioritize the substance of election disputes over mere procedural compliance.

The Court noted that Jaramilla focused solely on procedural technicalities without contesting the COMELEC’s finding of a manifest error in the tabulation of votes. Even at the COMELEC stage, Jaramilla failed to present any evidence to disprove the photocopies of the election returns and statement of votes that clearly showed the erroneous addition of 50 votes in his favor. The Supreme Court gave conclusive weight to the COMELEC’s factual findings, citing the principle that factual findings of the COMELEC, based on its assessments and duly supported by evidence, are conclusive in the absence of arbitrariness or grave abuse of discretion.

In affirming the COMELEC’s decision, the Supreme Court reiterated the importance of construing election laws liberally to give effect to the will of the people. The Court quoted Tatlonghari v. COMELEC, emphasizing that laws governing election contests must be liberally construed to ensure that the choice of public officials is not defeated by mere technical objections. The Court underscored that strict adherence to technicality that would validate a palpably void proclamation, and frustrate the people’s will, cannot be countenanced.

This decision highlights the COMELEC’s vital role in ensuring the integrity of elections. It underscores that the COMELEC is not merely a passive arbiter of election disputes but an active guardian of the electoral process. The power to correct manifest errors, even with the suspension of procedural rules, is essential for upholding the democratic principle that the true will of the people must prevail.

FAQs

What was the key issue in this case?	The key issue was whether the COMELEC acted with grave abuse of discretion in correcting a manifest error in the tabulation of votes, despite procedural lapses in the petition filed before it. The Supreme Court affirmed COMELEC’s authority to prioritize the correction of such errors in the interest of justice.
What is a manifest error in election law?	A manifest error refers to an obvious mistake in the tabulation or recording of votes that can be easily corrected without needing to examine the ballots themselves. This typically involves clerical errors in transferring data from election returns to the statement of votes.
Can the COMELEC suspend its own rules?	Yes, the COMELEC has the discretion to suspend its rules or any portion thereof in the interest of justice and to ensure the speedy disposition of matters pending before it. This power is provided for in Section 4, Rule 1 of the COMELEC Rules.
What happens if filing fees are not paid in a COMELEC case?	The COMELEC may refuse to take action on the case until the fees are paid, or it may dismiss the action or proceeding. However, the decision to dismiss is discretionary, as provided in Section 18, Rule 40 of the COMELEC Rules of Procedure.
Why is it important to liberally construe election laws?	Election laws must be liberally construed to ensure that the will of the people in the choice of public officials is not defeated by mere technical objections. This approach prioritizes the substance of elections over strict adherence to procedural formalities.
What is the difference between COMELEC’s administrative and quasi-judicial functions?	COMELEC’s administrative functions involve tasks like correcting manifest errors, while its quasi-judicial functions involve adjudicating disputes similar to court proceedings. The requirement for division-level hearings applies primarily to the quasi-judicial functions.
What was the basis for COMELEC’s decision in this case?	The COMELEC’s decision was based on the finding of a manifest error in the Statement of Votes by Precinct, where Alberto Jaramilla was credited with more votes than he actually received. This error was evident from a comparison of the election returns and the statement of votes.
What did the Supreme Court say about COMELEC’s factual findings?	The Supreme Court held that the factual findings of the COMELEC, based on its own assessments and duly supported by evidence, are given conclusive weight in the absence of arbitrariness or grave abuse of discretion.

In conclusion, the Supreme Court’s decision in Jaramilla v. COMELEC affirms the COMELEC’s broad authority to ensure fair and accurate elections by correcting manifest errors, even if it means relaxing certain procedural rules. This decision underscores the importance of safeguarding the integrity of the electoral process and upholding the will of the people.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

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: Alberto Jaramilla v. COMELEC, G.R. No. 155717, October 23, 2003