G.R. No. L-58575, September 21, 1983
CESAR JARDIEL, Petitioner, v. COMMISSION ON ELECTIONS and BENJAMIN AVES, Respondents.

FACTS

In the local elections of January 30, 1980, in Peñaranda, Nueva Ecija, petitioner Cesar Jardiel was proclaimed Mayor after defeating private respondent Benjamin Aves. The day after the election, the COMELEC received a telegraphic report from its own Special Action Team (COMSAT 9) recommending the annulment of the election results due to rampant flying voters, widespread terrorism, tampering of ballots, and the unjustified transfer of ballot boxes. On the same day, respondent Aves filed a formal letter-request echoing these allegations of massive irregularities and seeking annulment, which was docketed as P.P. Case No. 214.
The COMELEC proceeded with the case, requiring answers and conducting hearings where both parties submitted numerous affidavits and exhibits. Aves presented witnesses who were cross-examined. Notably, a separate complaint for election offenses filed by Aves with the COMELEC-deputized Ministry of Justice Election Task Force was later dismissed for insufficiency of evidence. Nevertheless, on December 10, 1980, the COMELEC (Second Division) issued a Resolution annulling the Peñaranda election and ordering a special election, primarily relying on the official report of its own COMSAT 9 and the totality of the evidence. Jardiel’s motion for reconsideration was denied, prompting this Petition for Certiorari.

ISSUE

Whether the COMELEC committed grave abuse of discretion in annulling the election in Peñaranda and ordering a special election.

RULING

The Supreme Court upheld the COMELEC’s Resolution, finding no grave abuse of discretion. The Court emphasized that the COMELEC’s factual findings, supported by substantial evidence, are generally binding. The COMELEC gave credence to the official telegraphic report of its own Special Action Team (COMSAT 9), which was created precisely to monitor election conduct. This report, describing serious and widespread venalities, was deemed a credible and authoritative piece of evidence that the COMELEC could rightfully prioritize in its assessment of the entire record, which included numerous affidavits from both sides.
The Court rejected Jardiel’s procedural and substantive arguments. First, the dismissal of the criminal complaint for election offenses by the Ministry of Justice Task Force does not constitute res judicata and does not bind the COMELEC. The Task Force was merely a deputized agency for criminal prosecution, whereas the COMELEC retains the constitutional prerogative to ensure free, honest, and orderly elections, which includes the administrative power to annul election results. Second, Jardiel’s proclamation and assumption of office did not divest the COMELEC of jurisdiction, as the case was properly treated as one for annulment of election, not a mere pre-proclamation controversy. Finally, the Court affirmed the COMELEC’s inherent power to call a special election when widespread terrorism vitiates the electoral process, as established in Sanchez v. COMELEC. The annulment and order for a special election were thus sustained.