GR L 52817; (November, 1984) (Digest)
G.R. No. L-52817 November 21, 1984
HERMILANDO C. ALCALA, ET AL., petitioners, vs. THE COMMISSION ON ELECTIONS, MARIO L. TAGARAO, ET AL., respondents.
FACTS
Two competing lists of candidates for local positions in Lucena City, both claiming to be the official Kilusang Bagong Lipunan (KBL) slate, were submitted to the COMELEC in early January 1980. One list was submitted by then Governor Anacleto Alcala, nominating the petitioners. The other list was submitted by incumbent Mayor Mario Tagarao, nominating the private respondents. The COMELEC, unable to secure a definitive clarification from the KBL national office and tasked with printing the official certified list of candidates, issued a resolution on January 19, 1980, recognizing Mayor Tagarao’s nominees as the official KBL candidates. Consequently, petitioners were listed as independent candidates on the official ballots. The election proceeded on January 30, 1980, with the private respondents winning and being proclaimed.
ISSUE
Whether the COMELEC committed grave abuse of discretion in recognizing the nominees of respondent Tagarao as the official KBL candidates, thereby listing petitioners as independents.
RULING
The Supreme Court dismissed the petition, finding no grave abuse of discretion by the COMELEC. The legal logic rests on two key principles. First, the electorate was fully informed of the competing slates and the COMELEC’s resolution prior to the election. The certified list of candidates, which clearly identified the official KBL candidates, was publicly posted. Thus, the voters made an informed choice, and their sovereign will, as expressed in the election results, must be respected. The Court emphasized the doctrine that election laws, mandatory before the election, become directory after the people have voted, and technicalities should not be used to overturn the clearly expressed will of the electorate.
Second, the COMELEC’s action was not arbitrary. Faced with two conflicting authorizations and the practical necessity of finalizing the ballot, the COMELEC made a reasonable determination. It considered that Tagarao, as the incumbent Mayor of Lucena City, had submitted a list supported by a later nomination from the KBL President. The COMELEC’s resolution was never repudiated by the KBL leadership. Therefore, its resolution was a valid exercise of its administrative discretion to ensure the orderly conduct of the election and did not amount to a capricious or whimsical act constituting grave abuse of discretion. The proper remedy for the petitioners was not to nullify the election results but a different pre-election or election protest, which they did not timely pursue.