G.R. No. 167224; September 21, 2007
NOLITO L. MAÑAGO, Petitioner, vs. COMMISSION ON ELECTIONS and NICANOR BIGAY, Respondents.

FACTS

Petitioner Nolito Mañago and private respondent Nicanor Bigay were candidates for Punong Barangay of Barangay Quinapaguian, Mercedes, Camarines Norte, in the July 15, 2002 elections. The initial canvass showed Mañago winning by one vote, 156 to 155, leading to his proclamation. Bigay filed an election protest before the Municipal Trial Court (MTC), praying for a judicial recount of the ballots in Precinct No. 71-A. After revision, the MTC found Bigay obtained 159 votes and Mañago 152, and consequently declared Bigay the duly elected Punong Barangay.
Mañago appealed to the COMELEC, arguing the MTC never acquired jurisdiction because Bigay allegedly failed to pay the correct filing fees. The COMELEC found that Bigay paid a total of One Hundred Fifty Pesos (₱150) through two official receipts, which complied with the prescribed fee under the COMELEC Rules. The COMELEC affirmed the MTC’s decision, also examining the contested ballots and validating votes for Bigay based on principles like idem sonans and the validity of nicknames listed in the certificate of candidacy.

ISSUE

Whether the COMELEC committed grave abuse of discretion in affirming the MTC decision which declared Nicanor Bigay the winner.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion by the COMELEC. On the jurisdictional issue, the Court held that payment of the filing fee was proper. The COMELEC correctly ruled that the total payment of ₱150, evidenced by official receipts, satisfied the legal requirement. Furthermore, the Court emphasized that Mañago actively participated in the protest proceedings without raising the fee issue at the earliest opportunity, effectively estopping him from challenging jurisdiction on that ground later.
On the substantive review of ballots, the COMELEC’s findings were supported by established legal principles in appreciating votes. The Court reiterated that election laws must be liberally construed to give effect to the will of the electorate, and technicalities should not defeat this paramount objective. The COMELEC’s detailed analysis of the contested ballots—applying doctrines on innocent erasures, idem sonans, use of nicknames, and the absence of marking—was a valid exercise of its adjudicatory power to determine the true result of the election. No capricious, whimsical, or despotic exercise of judgment was demonstrated; thus, no grave abuse of discretion warranting the Court’s corrective intervention existed.