G.R. No. 122250 & 122258, July 21, 1997
EDGARDO C. NOLASCO, petitioner, vs. COMMISSION ON ELECTIONS, MUNICIPAL BOARD OF CANVASSERS, MEYCAUAYAN, BULACAN, AND EDUARDO A. ALARILLA, respondents. FLORENTINO P. BLANCO, petitioner, vs. COMMISSION ON ELECTIONS AND EDUARDO A. ALARILLA, respondents.

FACTS

This case involves consolidated petitions concerning the mayoralty election in Meycauayan, Bulacan. Florentino P. Blanco was a candidate for mayor, and Edgardo C. Nolasco was the duly elected vice mayor. Eduardo A. Alarilla, another candidate, filed a petition to disqualify Blanco, alleging massive vote-buying in violation of Section 261(a) of BP 881. The Commission on Elections (COMELEC) issued an order disqualifying Blanco. The majority opinion of the Supreme Court upheld the COMELEC’s disqualification order as based on substantial evidence. However, Justice Bellosillo, in a Concurring and Dissenting Opinion, dissented from this specific finding.

ISSUE

The primary issue addressed in Justice Bellosillo’s opinion is whether the COMELEC order disqualifying Florentino P. Blanco as a mayoralty candidate for alleged vote-buying was based on substantial evidence.

RULING

Justice Bellosillo dissented from the majority’s finding that the disqualification order was based on substantial evidence. He voted to set aside the COMELEC order disqualifying Blanco. He argued that a careful scrutiny of the evidence presented by Alarilla failed to link Blanco to the alleged vote-buying. The evidence, including affidavits, a video tape, photographs, identification cards, and handwritten admissions, was found to be insufficient, contrived, inconsistent, and doubtful. For instance, affidavits were executed on fill-in-the-blanks forms a month after the petition was filed and were not substantiated by presenting the affiants. Allegations about the amount of money in envelopes were inconsistent. A video tape was not viewed by the COMELEC. Photographs and identification cards were, by themselves, meaningless as evidence of vote-buying. Handwritten admissions contained identical wordings and incorrect addresses. Justice Bellosillo concluded that the evidence was too inadequate and fell short of the standard of substantial evidence—relevant evidence which a reasonable mind would accept as adequate to support a conclusion. He found that the COMELEC gravely abused its discretion by basing its findings on unfounded assumptions and unsubstantiated allegations.
However, Justice Bellosillo concurred with the majority’s application of the “Labo doctrine,” stating that if Blanco is disqualified, a permanent vacancy occurs in the office of mayor because he “fails to qualify” under Section 44(a) of the Local Government Code. Consequently, the duly elected vice mayor, Edgardo C. Nolasco, should rightfully succeed to the position.