G.R. No. L-1888; March 23, 1948
BATO ALI, petitioner, vs. THE COURT OF FIRST INSTANCE OF LANAO and NATANCOP INDOL, respondents.

G.R. No. L-1889; March 23, 1948
ISMAEL MAROHON, petitioner, vs. THE COURT OF FIRST INSTANCE OF LANAO and MACAORAO BALINDONG, respondents.

FACTS

Two election protests were filed in the Court of First Instance of Lanao by Bato Ali and Ismael Marohon, who were candidates for municipal mayor in Dansalan and Malabang, respectively, in the November 11, 1947 elections. They were proclaimed to have received the second-highest number of votes. Their motions of protest alleged they were candidates, stated the votes received by them and the protestees, and noted the protestees’ proclamation as winners. The protestees moved to dismiss, arguing the motions failed to allege two jurisdictional facts: that the protestants “were candidates voted for” and that they “presented a certificate of candidacy.” The trial court denied the motions to dismiss, prompting the protestees to file these petitions for prohibition.

ISSUE

Whether the motions of protest sufficiently alleged the jurisdictional facts necessary to confer jurisdiction upon the Court of First Instance over the election contests.

RULING

The Supreme Court denied the petitions, holding that the motions of protest sufficiently alleged the jurisdictional facts. The allegation that the protestants were “candidates” and “placed second” in the voting necessarily implies they were voted for and had filed certificates of candidacy. The Court emphasized that pleadings in election cases should be liberally construed to effectuate the people’s will, and jurisdictional facts need not be alleged in precise statutory language if they can be gathered substantially from the allegations. The doctrine in Tengco v. Jocson was not departed from, as it only requires jurisdictional facts to appear on the face of the proceedings, not in sacramental words.

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