GR 166046; (March, 2006) (Digest)
G.R. No. 166046, March 23, 2006
MARGARITO C. SULIGUIN, Petitioner, vs. THE COMMISSION ON ELECTIONS, THE MUNICIPAL BOARD OF CANVASSERS OF NAGCARLAN, LAGUNA, and ECELSON C. SUMAGUE, Respondents.
FACTS
Petitioner Margarito Suliguin and respondent Ecelson Sumague were candidates for Sangguniang Bayan of Nagcarlan, Laguna, in the May 10, 2004 elections. The Municipal Board of Canvassers (MBOC) convened and, due to an error in addition in the Statement of Votes, credited Sumague with only 644 votes from certain precincts instead of his actual 844 votes. This mistake resulted in Suliguin being proclaimed the 8th winning councilor with 6,605 votes, while Sumague’s correct total was 6,647 votes. The MBOC attributed the error to extreme fatigue.
Upon discovery, the MBOC filed a “Petition to Correct Entries” with the COMELEC on May 26, 2004. The COMELEC First Division granted the petition, nullified Suliguin’s proclamation, and ordered the MBOC to correct the Statement of Votes and proclaim Sumague. Suliguin’s motion for reconsideration was denied by the COMELEC En Banc, prompting this petition for certiorari.
ISSUE
Whether the COMELEC committed grave abuse of discretion in granting the MBOC’s petition to correct manifest errors in the Statement of Votes and in nullifying Suliguin’s proclamation.
RULING
The Supreme Court dismissed the petition, finding no grave abuse of discretion by the COMELEC. The Court emphasized that the COMELEC’s constitutional mandate is to ascertain by all means the true will of the electorate. The discrepancy was a clear case of a manifest error in the addition of votes, which falls under the COMELEC’s authority to correct even after a proclamation, to ensure the true election results are reflected.
The Court rejected Suliguin’s procedural objections regarding the timeliness of the petition and the MBOC’s authority to file it. It ruled that technicalities of procedure must yield to the public interest in determining the real winner in an election. The COMELEC Rules of Procedure are to be liberally construed to achieve this end. The MBOC, though arguably functus officio after proclamation, properly sought correction of a clerical error to give effect to the legitimate vote count. The mathematical error was indisputable, and correction was necessary to proclaim the candidate with the higher number of valid votes.