G.R. No. 201672 ; August 13, 2013
CESAR G. MANALO, PETITIONER, vs. COMMISSION ON ELECTIONS, DEPARTMENT OF INTERIOR AND LOCAL GOVERNMENT AND ERNESTO M. MIRANDA, RESPONDENTS.

FACTS

Petitioner Cesar G. Manalo and private respondent Ernesto M. Miranda were candidates for Punong Barangay of Sta. Maria, Mabalacat, Pampanga in the 2010 elections. Miranda was initially proclaimed the winner by a margin of one vote (344 to 343). Manalo filed an election protest before the Municipal Circuit Trial Court (MCTC). After a revision and appreciation of ballots, the MCTC declared Manalo the winner with 344 votes against Miranda’s 333 votes, a plurality of 11 votes. The MCTC thus nullified Miranda’s proclamation and declared Manalo the duly elected Punong Barangay.
Miranda appealed the MCTC decision to the COMELEC. Manalo, meanwhile, filed a Motion for Immediate Execution of the MCTC Decision Pending Appeal, which the trial court granted. The MCTC cited good reasons: the victory of the protestant was clearly established, public interest demanded respect for the true electorate’s choice, and public policy required striking a blow against the “grab-the-proclamation-prolong-the-protest” technique. Miranda then filed a Petition for Certiorari with the COMELEC, assailing the grant of execution pending appeal. The COMELEC Second Division and later the COMELEC En Banc granted Miranda’s petition, annulling the MCTC’s Special Order for execution pending appeal. This prompted Manalo to elevate the case to the Supreme Court via a Petition for Certiorari.

ISSUE

Whether the COMELEC committed grave abuse of discretion in annulling the MCTC’s Special Order granting execution of its decision pending appeal.

RULING

Yes, the Supreme Court ruled that the COMELEC committed grave abuse of discretion. The Court emphasized that execution pending appeal in election cases is governed by Section 11, Rule 14 of A.M. No. 07-4-15-SC (Rules of Procedure in Election Contests Before the Courts Involving Elective Municipal and Barangay Officials). The rule permits it for “good reasons” stated in a special order. The MCTC’s stated reasons—the clearly established victory, public interest in installing the true choice, and the policy against prolonging protests—constitute valid “good reasons” as consistently recognized in jurisprudence, such as Ramas v. COMELEC and Balajonda v. COMELEC.
The COMELEC’s reversal substituted its own judgment for the trial court’s discretion without demonstrating that such discretion was exercised arbitrarily or capriciously. The trial court, having heard the evidence and examined the ballots, was in the best position to determine the existence of good reasons. By nullifying the Special Order, the COMELEC effectively disregarded established doctrine and the trial court’s factual findings, thereby acting with grave abuse of discretion amounting to lack or excess of jurisdiction. Consequently, the Supreme Court reversed the COMELEC Resolutions, made permanent its own Temporary Restraining Order, and ordered the remand of the case to the MCTC for the immediate execution of its May 24, 2011 Decision.