GR L 25444; (January, 1966) (Digest)
G.R. No. L-25444; January 31, 1966
WENCESLAO RANCAP LAGUMBAY, petitioner, vs. THE COMMISSION ON ELECTIONS and CESAR CLIMACO, respondents.
FACTS
The petitioner sought a review of an order from the Commission on Elections (COMELEC) which declined to reject the election returns from certain precincts in Mindanao municipalities. The returns exhibited statistically improbable patterns: in one set, the number of registered voters equaled the number of ballots and votes tallied, with every candidate from the Liberal Party receiving all votes and every candidate from the Nacionalista Party receiving exactly zero votes. In another set, all votes were for Liberal Party candidates, each credited with identical vote counts per precinct (e.g., 240 to 650), while all Nacionalista Party candidates received exactly zero. The Supreme Court, treating the matter as urgent, initially issued a resolution on December 24, 1965, upholding COMELEC’s power to reject these returns as “obviously manufactured.”
ISSUE
Whether the Commission on Elections correctly declined to reject the subject election returns, which showed all votes cast in a precinct going uniformly to all candidates of one party and zero votes to all candidates of the opposing party.
RULING
The Supreme Court DENIED the motion for reconsideration and the petition for rehearing, thereby AFFIRMING its resolution that the COMELEC has the power and duty to reject the returns from the questioned precincts. The Court ruled that such returns are “obviously manufactured” or false prima facie. The uniform 100% block-voting results are utterly improbable and contrary to statistical realities, as not all voters fill all senatorial slots and nationwide party presence makes a total shutout unlikely. The Court applied the principle from Mitchell v. Stevens that manifestly fabricated returns, where fraud is palpable from the return itself (res ipsa loquitur), need not be accepted at face value. This approach counters the pernicious “grab-the-proclamation-prolong-the-protest” strategy. The Court clarified that this ruling does not usurp the Senate Electoral Tribunal’s functions, as the ultimate verdict on these votes may still be ascertained in an election protest.