G.R. No. 157687 & 158959; February 26, 2004
FERNANDO U. BATUL, petitioner, vs. LUCILO BAYRON and COMMISSION ON ELECTIONS (First Division), respondents.

FACTS

Petitioner Fernando Batul and respondent Lucilo Bayron were candidates for Vice-Mayor of Puerto Princesa City in the May 2001 elections. Batul was proclaimed winner. Bayron filed an election protest. After revision of ballots, Bayron’s summary showed he garnered more votes. During the presentation of his evidence, Batul sought to present 50 Board of Election Inspectors (BEI) chairpersons to testify on the genuineness of signatures at the back of ballots from precincts where vote reversals occurred. The COMELEC First Division denied this motion in its Order dated February 12, 2003, and denied reconsideration on March 21, 2003. Batul filed a petition for certiorari (G.R. No. 157687) challenging these orders.
While G.R. No. 157687 was pending, the COMELEC First Division promulgated its Resolution on July 2, 2003, annulling Batul’s proclamation and declaring Bayron the winner. The COMELEC issued an Order and Writ of Execution on July 21, 2003. Batul filed a second petition (G.R. No. 158959) assailing this writ, arguing the COMELEC decision was not yet final as his motion for reconsideration was still pending.

ISSUE

The primary issue is whether the COMELEC First Division committed grave abuse of discretion in denying Batul’s motion to present 50 BEI chairpersons as witnesses. A corollary issue is whether the COMELEC First Division’s Resolution of July 2, 2003, had attained finality to justify the issuance of the writ of execution.

RULING

The Supreme Court dismissed the petitions. On the first issue, the COMELEC did not commit grave abuse of discretion in denying the presentation of the 50 BEI chairpersons. The purpose of the testimony was to challenge the ballots’ authenticity by questioning the BEI signatures. The legal logic is that the absence or presence of BEI signatures on ballots is not a ground for their invalidation under the Omnibus Election Code. Ballots are considered valid and should be counted if they bear the required markings and do not contain identifying features, irrespective of BEI signatures. Therefore, the proposed testimony was immaterial and would not have affected the election results. The COMELEC’s exclusion of superfluous evidence was within its discretion.
On the second issue, the COMELEC Resolution had attained finality. Batul filed a motion for reconsideration with the COMELEC First Division. However, under COMELEC Rules of Procedure, a motion for reconsideration of a Division ruling must be certified to the Commission en banc. Batul’s failure to comply with this rule meant his motion did not suspend the finality of the decision. Consequently, the Resolution became final after fifteen days, and the issuance of the writ of execution was proper. The Court emphasized that procedural rules are designed to ensure the orderly administration of justice and the speedy disposition of election cases, which are imbued with public interest.