GR 170300; (February, 2007) (Digest)
G.R. No. 170300 ; February 9, 2007
Bartolome Balingit, Petitioner, vs. Commission on Elections and Pablo Yamat, Respondents.
FACTS
In the July 2002 barangay elections for Punong Barangay of Nigui, Masantol, Pampanga, Pablo Yamat was initially proclaimed winner with 257 votes against Bartolome Balingit’s 250. Balingit filed an election protest. After revision, the Municipal Circuit Trial Court (MCTC) invalidated 86 ballots and, in a September 2003 Decision, declared Balingit the winner with 249 votes to Yamat’s 172. Yamat appealed to the COMELEC. The COMELEC Second Division, in an April 2005 Resolution, reversed the MCTC. It validated 80 of the 86 invalidated ballots, crediting them to Yamat, resulting in a final tally of 252 votes for Yamat and 249 for Balingit. Commissioner Mehol Sadain dissented, arguing that six specific ballots among the 80 appeared written by one person and should be invalidated, which would make Balingit the winner. The COMELEC En Banc denied Balingit’s Motion for Reconsideration in November 2005, ordering him to vacate the office.
ISSUE
Whether the COMELEC committed grave abuse of discretion in its appreciation of the contested ballots and in issuing its Resolutions.
RULING
The Supreme Court dismissed the petition, finding no grave abuse of discretion by the COMELEC. The legal logic centers on the nature of a certiorari petition and the COMELEC’s mandate. Grave abuse of discretion implies a capricious, whimsical, or despotic exercise of judgment equivalent to lack of jurisdiction. The Court held that the COMELEC’s factual findings on ballot appreciation, including its decision to validate the 80 ballots, are generally conclusive and not subject to review unless shown to be devoid of rational basis. The COMELEC meticulously examined the ballots and provided specific justifications for its rulings, which fell within its specialized competence. The dissent of one Commissioner does not, by itself, prove arbitrariness in the majority’s conclusion. Regarding the order for Balingit to vacate the office citing the “proximity of the end of the term,” the Court noted the COMELEC’s erroneous reference given the extension of terms under Republic Act No. 9340 . However, this mistake was deemed a mere error of judgment, not a grave abuse of discretion, as it did not vitiate the core validity of the Resolutions which correctly applied election laws on ballot appreciation. The COMELEC’s ultimate proclamation of Yamat was upheld.