GR 199433; (November, 2012) (Digest)
G.R. No. 199433 ; November 13, 2012
ISABELITA P. GRAVIDES, Petitioner, vs. COMMISSION ON ELECTIONS and PEDRO C. BORJAL, Respondents.
FACTS
Petitioner Isabelita P. Gravides and private respondent Pedro C. Borjal were candidates for Punong Barangay of Barangay U.P. Campus, Quezon City, in the October 25, 2010 elections. Gravides was proclaimed winner with 2,322 votes against Borjal’s 2,320 votes. Borjal filed an election protest before the Metropolitan Trial Court (MeTC), alleging various irregularities including misreading of ballots, mis-tallying of votes, and the counting of invalid ballots. Gravides filed her Answer, arguing the protest contained only general allegations and failed to comply with procedural rules.
The MeTC issued a Notice of Pre-Trial Conference, warning that failure to appear could cause dismissal. During the preliminary conference, Gravides moved to dismiss the protest for Borjal’s alleged non-compliance with Section 4, Rule 9 of A.M. No. 07-4-15-SC (the Rules on Election Contests), which requires a detailed preliminary conference brief. The MeTC granted the motion and dismissed the protest. Borjal appealed to the COMELEC.
ISSUE
Whether the COMELEC committed grave abuse of discretion in reversing the MeTC’s dismissal of the election protest for non-compliance with procedural rules on the preliminary conference brief.
RULING
The Supreme Court ruled that the COMELEC did not commit grave abuse of discretion. The legal logic centers on the proper application of procedural rules and the COMELEC’s broad appellate authority. The MeTC erred in strictly applying the rules on preliminary conference briefs to dismiss the protest. A.M. No. 07-4-15-SC mandates that such a brief must contain specific items, including a summary of admitted facts and the issues to be tried. However, procedural rules in election cases should be liberally construed to achieve their paramount objective: to ascertain the will of the electorate.
The COMELEC correctly found that Borjal’s filing of a preliminary conference brief, albeit potentially deficient in form, substantially complied with the rules. His brief outlined the contested precincts and the nature of the alleged irregularities. Dismissing the protest on purely technical grounds would subvert the people’s right to have their true choice determined. The COMELEC, vested with exclusive appellate jurisdiction over such contests, acted within its discretion in reinstating the protest to allow a hearing on the merits. The Supreme Court affirmed that certiorari requires a showing of capricious, arbitrary, or despotic exercise of power, which was absent. The COMELEC’s decision to prioritize substantive justice over technicality was a proper exercise of its jurisdiction.