G.R. No. 142507 ; December 1, 2000
ALFREDO U. MALABAGUIO, petitioner, vs. THE COMMISSION ON ELECTIONS and MIRALI MENDOZA-DURR, respondents.

FACTS

Petitioner Alfredo Malabaguio and private respondent Mirali Mendoza-Durr were candidates for Punong Barangay of Barangay 172, Kalookan City, in the May 12, 1997 elections. Mendoza-Durr was initially proclaimed the winner. Malabaguio filed an election protest before the Metropolitan Trial Court (MeTC), which, after revision, declared him the winner. The MeTC also granted his motion for execution pending appeal. Mendoza-Durr appealed to the COMELEC and filed a separate petition challenging the execution order.
The COMELEC Second Division reversed the MeTC decision and declared Mendoza-Durr the duly elected Punong Barangay. In its appreciation of ballots, the COMELEC invalidated 57 ballots cast for Malabaguio from two precincts because they lacked the signature of the Chairman of the Board of Election Inspectors (BEI) on their back. Malabaguio filed a motion for reconsideration, arguing the disenfranchisement of the voters and denial of due process. The COMELEC En Banc denied his motion, affirming the Second Division’s ruling.

ISSUE

Whether the COMELEC committed grave abuse of discretion in invalidating the 57 ballots for lacking the BEI Chairman’s signature, thereby disregarding the intent of the voters and the principle of liberality in ballot appreciation.

RULING

Yes. The Supreme Court granted the petition, setting aside the COMELEC resolutions and reinstating the MeTC decision declaring Malabaguio the winner. The Court held that the COMELEC’s strict, literal application of the rule requiring the BEI Chairman’s signature on the ballot’s back constituted grave abuse of discretion. The paramount objective of election laws is to give effect to the sovereign will of the people. Technical rules and formalistic defects should not defeat the clear intent of the voter.
The absence of the BEI Chairman’s signature is a mere irregularity that does not justify disenfranchising voters, especially when there is no evidence of fraud or that the ballots were spurious. The Court emphasized the doctrine of liberal interpretation in appreciating ballots, where the voter’s intent is paramount. Invalidating these ballots on a purely technical ground, without a showing that their integrity was compromised, subverts the democratic process. The will of the electorate, as discerned from the ballots themselves, must prevail over rigid formalities. Consequently, the 57 ballots were ruled valid and counted for Malabaguio, making him the rightful winner.