G.R. No. 134340 November 25, 1999
LININDING PANGANDAMAN, petitioner, vs. COMMISSION ON ELECTIONS, PROVINCIAL BOARD OF CANVASSERS OF LANAO DEL SUR, MAHED MUTILAN, ALEEM, AMERRODIN SARANGANI and NARRA ABDUL JABBAR JIALIL, respondents.

FACTS

This case involves a petition for certiorari and prohibition challenging the COMELEC En Banc’s Omnibus Order dated July 14, 1998, which declared a failure of elections in several municipalities of Lanao del Sur and scheduled special elections. The COMELEC found that a total failure of elections occurred in twelve municipalities due to causes such as armed confrontations between political groups, vehement disagreements on precinct clustering, terrorization preventing the distribution of ballots, and the disqualification of almost all appointed Board of Election Inspectors (BEIs) due to prohibited relationships with candidates. A partial failure of elections was also declared in five other areas. The COMELEC ordered the holding of special elections on July 18 and 25, 1998, to be conducted via machine counting, except in specified areas.
Petitioner Lininding Pangandaman sought to annul this Omnibus Order, arguing that the COMELEC gravely abused its discretion in declaring a failure of elections. He contended that the grounds cited, such as the disqualification of BEIs, did not constitute a valid cause for declaring a failure of elections under the law. He further challenged the composition of the BEIs for the special elections and the use of machine counting.

ISSUE

Whether the COMELEC committed grave abuse of discretion in issuing the Omnibus Order declaring a failure of elections and scheduling special elections in the affected municipalities of Lanao del Sur.

RULING

The Supreme Court DISMISSED the petition. The Court held that the petition had been rendered moot and supervening events had overtaken it. The special elections scheduled for July 18 and 25, 1998, which the petition sought to enjoin, had already been conducted. Furthermore, the Certificates of Canvass of Votes and Proclamation of the Winning Candidates had already been issued by August 7, 1998. The Court emphasized that election laws must be liberally construed to uphold the sovereignty of the people, and technicalities should not defeat the will of the electorate. The COMELEC’s factual findings, based on reports from field officers and admissions from parties during pre-trial, established that no precincts functioned in the twelve municipalities on election day due to the cited causes, which effectively prevented the free and orderly conduct of elections. This constituted a valid basis for declaring a failure of elections under the law. The Court found no grave abuse of discretion in the COMELEC’s order, as it was a necessary measure to give effect to the people’s right of suffrage. To nullify the special elections and order a re-canvass of non-existent votes from the failed May elections, as petitioner insisted, would be an unwarranted imposition and contrary to substantial justice.