G.R. No. 143351 & 144129; September 14, 2000
MA. AMELITA C. VILLAROSA, petitioner, vs. THE HOUSE OF REPRESENTATIVES ELECTORAL TRIBUNAL and RICARDO V. QUINTOS, respondents.

FACTS

Petitioner Ma. Amelita C. Villarosa and private respondent Ricardo V. Quintos were candidates for Representative of Occidental Mindoro in the May 1998 elections. Villarosa was proclaimed winner. Quintos filed an election protest before the House of Representatives Electoral Tribunal (HRET), contesting all precincts. A critical issue was the validity of ballots marked “JTV” for the congressional position. Villarosa had registered “JTV” as her nickname, but the COMELEC, in a resolution issued on election day, canceled her use of it, ruling “JTV” was not her popular nickname but that of her husband, former Representative Jose T. Villarosa. Villarosa challenged this COMELEC resolution in the Supreme Court in a separate pending case.
During the HRET revision of ballots from designated pilot precincts, the revisors classified ballots with “JTV” and similar variations as votes for Villarosa, over Quintos’s objection. The HRET ultimately ruled these “JTV” ballots as stray votes. It concluded that the COMELEC’s resolution, issued before the elections and received by the Provincial Election Supervisor on election day, was valid and binding. Consequently, the HRET deducted these votes from Villarosa’s total, resulting in a finding that Quintos won by a margin of 2,837 votes.

ISSUE

Whether the HRET committed grave abuse of discretion in ruling that ballots bearing “JTV” and similar markings are stray votes not countable for petitioner Villarosa.

RULING

The Supreme Court dismissed the petitions, finding no grave abuse of discretion by the HRET. The legal logic rests on the HRET’s constitutional mandate as the sole judge of congressional election contests, enjoying jurisdiction that is exclusive and beyond judicial interference absent a clear showing of grave abuse. The Court emphasized that the HRET’s appreciation of ballots, including its determination of whether a nickname identifies a candidate, is within its specialized competence.
The HRET’s decision to treat “JTV” ballots as stray was based on its factual finding that “JTV” was not Villarosa’s popular nickname but her husband’s, a finding supported by the COMELEC’s valid resolution. The HRET correctly applied Section 211(14) of the Omnibus Election Code, which mandates that a vote containing only initials that do not sufficiently identify the candidate is stray. The HRET acted within its authority in giving effect to the COMELEC resolution, which was issued under its administrative power to enforce election laws and was received by local officials before the closing of polls. The Court found no capricious, whimsical, or arbitrary exercise of judgment that would constitute grave abuse of discretion warranting the nullification of the HRET’s factual and legal conclusions.