G.R. No. L-32683. May 31, 1971. BUENAVENTURA OBANDO, petitioner, vs. URBANO REGIS, respondent.
FACTS

This is a direct appeal on questions of law from a decision of the Court of First Instance of Cebu in an election protest. The protest concerned the 1967 elections for Vice-Mayor and councilors in Naga, Cebu. After the examination of contested and uncontested ballots by Commissioners, the trial court adopted a procedure where parties submitted written statements enumerating their objections and claims per precinct. The court then rendered a decision laying down general principles for ballot appreciation, such as invalidating ballots with figures before councilor names as distinguishing marks, but did not specify which individual ballots were rejected or admitted under these rules.
Instead, the decision merely provided summary tabulations, showing only the final number of contested votes credited to each candidate per precinct. For example, it listed that protestant Urbano Regis received 17 votes in Precinct 1, while protestee Buenaventura Obando received 59, without detailing the specific ballots counted or the reasons for crediting or rejecting each. Obando moved for reconsideration, arguing this method prevented identification of ballots and verification of the counts, but the motion was denied, with the court stating that enumerating each ballot would unnecessarily lengthen the decision.

ISSUE

Whether the trial court’s decision, which failed to specify the individual ballots admitted or rejected and the reasons applied to each, complies with the legal requirement for judgments to state clearly and distinctly the facts and the law on which they are based.

RULING

No. The Supreme Court ruled the decision was incomplete and inoperative for failing to comply with Section 1, Rule 36 of the Revised Rules of Court, which mandates that judgments must state clearly and distinctly the facts and the law on which they are based. The Court acknowledged that a trial court is not required to discuss each ballot separately and may group ballots where a common ruling applies. However, it is essential to specify which ballots a particular ruling is applied to and what that ruling is in each instance.
The method used by the lower court, providing only numerical summaries without enabling the identification of ballots or the reasons for their admission or rejection, rendered its decision unreviewable. It deprived the parties of the ability to determine the correctness of the court’s actions for a meaningful motion for reconsideration and prevented the Supreme Court from judging whether the rulings conformed to law. While regretting the resulting delay, the Court emphasized that approving such a deficient decision would set a pernicious precedent. The decision was thus set aside and the case remanded to the trial court with instructions to complete the decision in conformity with this opinion.