GR 124383; (August, 1996) (Digest)
G.R. No. 124383 August 9, 1996
CORAZON L. CABAGNOT, petitioner, vs. COMMISSION ON ELECTIONS and FLORENCIO T. MIRAFLORES, respondents.
FACTS
Petitioner Corazon L. Cabagnot and private respondent Florencio T. Miraflores were candidates for Governor of Aklan in the May 1995 elections. Miraflores was proclaimed winner. Cabagnot filed an election protest, docketed as EPC No. 95-25. The Comelec First Division issued an Order dated January 23, 1996, designating Kalibo, Aklan as the venue for the revision of ballots. Cabagnot filed a motion for reconsideration, praying that the revision be held in Manila at the Comelec Main Office to ensure neutrality and to insulate the proceedings from local partisan influence, offering to shoulder the associated expenses. The Comelec En Banc denied the motion, ruling that the designation of venue was within its discretion, provided the integrity of the proceedings was protected.
ISSUE
Whether the Commission on Elections committed grave abuse of discretion in denying the motion to hold the revision of ballots in Manila and in designating Kalibo, Aklan as the venue.
RULING
Yes, the Comelec committed grave abuse of discretion. The Court ruled that while the Comelec possesses discretion in determining the venue for revision, such discretion must be exercised within the bounds of its own rules and with consistency. Section 9 of Comelec Rule 20 provides that the revision shall be made in the office of the Clerk of Court at the Main Office in Manila, or at such other place as the Commission may designate. The Comelec’s belated justification for the change—lack of storage space in Manila—was deemed insufficient, especially when weighed against the paramount need for a neutral venue to safeguard the integrity of the electoral process.
Crucially, the Court found that the Comelec reversed its own established doctrine without rational basis. In several prior and analogous election protest cases, such as those involving Guingona, Antonio, Gustilo, Trinidad, and Binay, the Comelec had consistently granted requests and issued orders holding the revision proceedings in its Manila head office, which this Court had subsequently upheld. This inconsistency, without a compelling reason, constituted arbitrary action. The practical considerations cited in those prior cases—that it would be expensive, time-consuming, and impractical for the Commissioners to travel to the provinces to supervise or review the revision—applied with equal force to the instant case. Therefore, the Comelec’s departure from its consistent practice amounted to grave abuse of discretion warranting judicial correction.