G.R. No. L-4479
SILVESTRE ARZADON, plaintiff, vs. DIONISIO CHANCO, judge of First Instance of Ilocos Norte, and LORENZO BALDUEZA, defendants.
January 10, 1910

FACTS:
Silvestre Arzadon obtained a majority of votes for municipal president of Badoc, Ilocos Norte, in the November 5, 1907 elections. A protest was lodged against his election in the Court of First Instance (CFI) by the respondents, alleging violations of Section 30, paragraph 3 of the Election Law (Act No. 1582).

The CFI found that Arzadon had, since 1903, organized a group of electors, promising them non-employment in town work and assistance in legal matters at the group’s expense. He also distributed pre-filled ballots and offered money or inducements to influence votes. The CFI concluded that Arzadon violated the Election Law’s prohibition against actions, influence, and promises made to obtain votes.

Consequently, the CFI declared Arzadon’s election illegal, ordered a special election, declared Arzadon ineligible for that special election (stating any vote for him would not count), and charged him with the expenses of both the special election and the protest proceedings.

Arzadon then instituted certiorari proceedings before the Supreme Court, seeking to annul the CFI’s decision insofar as it declared him ineligible for the special election and ordered him to bear the expenses of said election.

ISSUE:
Did the Court of First Instance exceed its jurisdiction in an election protest by declaring the protested candidate ineligible for future elections and by ordering him to bear the expenses of the new election?

RULING:
Yes, the Court of First Instance exceeded its jurisdiction.

The Supreme Court held that certiorari was the proper remedy because decisions of Courts of First Instance in election contests are exclusive and final under Section 27 of the Election Law, thus precluding appeal.

The Court found that while Section 27 of the Election Law conferred upon Courts of First Instance the authority to hear election protests, neither this section nor any other legal provision authorized the court to declare a person ineligible for future elections or to sentence him to pay the expenses of a new election. These specific rulings were beyond the scope of the CFI’s power in an election contest.

Therefore, the Supreme Court annulled the CFI’s judgment insofar as it declared Silvestre Arzadon ineligible at the special election ordered therein and imposed upon him the obligation to bear the expenses of such election. The Court did not rule on the propriety of ordering a special election itself, as that part of the CFI’s decision was not challenged by the petitioner.