21. Manzala vs. Commission on Elections
G. R. No. 176211, May 8, 2007 Appellate jurisdiction jurisdiction of Coelec
FACTS: Petitioner
Ibarra R. Manzala and private respondent Julie R. Monton were were mayora mayoralty lty candid candidate ates s in the Munici Municipal pality ity of Magdiw Magdiwang, ang, Romblon omblon,, during the May 1, !" #ational and $ocal %lections. &n May 1', !", the Municipal (oard of )anvassers proclaimed private respondent as the duly elected Municipal Mayor with !,*+ votes, or a margin of 1' votes, over petitioners !,*-- votes. &n May 1, !", petitioner led an election protest with the R/) of Romblon see0ing recount in the 1 precincts of Magdiwang on the grounds of fraud, seriou serious s irre irregul gulari aritie ties, s, and willfu willfull violat violation ion of the &mnib &mnibus us %lecti %lection on )ode )ode (atas Pambansa (ilang 2213 and other pertinent )&M%$%) rules allegedly committed by the voters and the )hairman and members of the (oard of %lection Inspectors during the election.
/he trial court rendered 4udgment 4udgment in favor of petitioner. petitioner. Petitioner Petitioner moved for the e5ecution e5ecution of the decision pending appeal which the trial court granted on 6ecember 1-, !*. &n 7ugust !", !-, the 8ormer 9econd 6ivision of the )&M%$%) issued a Resolution which reversed and set aside the decision of the trial court. It found that private respondent obtained !,*- votes, or a margin of 1+ votes, over petitioners !,*"' votes. Petitioner:s motion for reconsideration was denied by the )&M%$%) %n (anc in its Resolution of January !", !+. It later a;rmed the earlier Resolution dated 7ugust !", !-. &n 8ebru ebruar ary y 1, ! !+ +,, peti petiti tion oner er led led this this peti petiti tion on for for cert certio iora rari ri and and prohibition. ISSUE:
1. !.
<&# <&# )&M% )&M%$% $%) ) has has appe appell llat ate e 4uri 4urisd sdic icti tion on to to rev revie iew, w, rev revis ise, e, mod modif ify, y, or even reverse and set aside the decision of the R/)= <&# the the R/ R/):s ):s rul ruling ing on the the vali validi dity ty of of the the ball ballot ots s shoul should d not be be disturbed
HELD:
1.
>es. es. 6eci 6ecisi sion ons, s, nal nal or orders ders,, or rul rulin ings gs of the the )om )ommi missi ssion on on on elec electi tion on contests involving elective municipal and barangay o;ces shall be nal, nal, e5ecut ecutor ory, y, and and not not appe appeal alab able le.. In the the e5erci ercise se of its its ad4u ad4udi dica cato tory ry or ?uas ?uasi@ i@4u 4udi dici cial al powe powers rs,, the the )ons )onsti titu tuti tion on also also
mandates the )&M%$%) to hear and decide cases rst by division and upon motion for reconsideration, by the )&M%$%) en banc. %lection cases cannot be treated in a similar manner as criminal cases where, upon appeal from a conviction by the trial court, the whole case is thrown open for review and the appellate court can resolve issues which are not even set forth in the pleadings. In the present case, the )&M%$%) en banc had thoroughly reviewed the decision of its 8ormer 9econd 6ivision and a;rmed the ndings thereof with modication as to the number of votes obtained by both parties after re@appreciation, that is, private respondent obtained !,*'* votes, or a margin of - votes, over petitioners !,"+* votes. !.
#o. /he appreciation of the contested ballots and election documents involves a ?uestion of fact best left to the determination of the )&M%$%), a specialized agency tas0ed with the supervision of elections all over the country. /o reiterate, the )&M%$%) is the constitutional commission vested with the e5clusive original 4urisdiction over election contests involving regional, provincial and city o;cials, as well as appellate 4urisdiction over election protests involving elective municipal and barangay o;cials.
