G.R. No. L-49705-09 and L-49717-21 February 8, 1979
Tomatic Aratuc, Sergio Tocao, Ciscolario Diaz, Fred Tamula, Mangontawar Guro and Bonifacio Legaspi, petitioners, vs. The Commission on Elections, Regional Board of Canvassers for Region XII (Central Mindanao), Abdullah Dimaporo, Jesus Amparo, Anacleto Badoy, et al., respondents. (Consolidated with Linang Mandangan, petitioner, vs. The Commission on Elections, The Regional Board of Canvassers for Region XII, and Ernesto Roldan, respondents.)

FACTS

These consolidated petitions for certiorari arose from the April 7, 1978 elections for representatives to the Interim Batasang Pambansa in Region XII. Petitioners were independent candidates under the unregistered “Kunsensiya ng Bayan” banner. They initially secured from the Supreme Court a restraining order against the regional canvass, alleging massive irregularities in numerous voting centers across several provinces. The Court subsequently allowed the canvass to resume in Manila under specific guidelines, directing the Commission on Elections (COMELEC) and the Board of Canvassers to give petitioners ample opportunity to object to returns and to exclude those where fraud was evident from a summary scrutiny of election records.
The canvass proceeded, and the COMELEC ultimately proclaimed eight winners from the Kilusang Bagong Lipunan (KBL), the administration party. Petitioners appealed to the COMELEC, arguing that the Board and the COMELEC disregarded the Supreme Court’s guidelines by failing to conduct a proper summary scrutiny of the records they presented and by including returns that were statistically improbable and manifestly fraudulent. The COMELEC denied their appeals. Petitioners now allege that the COMELEC committed grave abuse of discretion in affirming the canvass and the proclamation.

ISSUE

Whether the Commission on Elections committed grave abuse of discretion amounting to lack or excess of jurisdiction in its resolution of the petitioners’ appeals against the canvass and proclamation of winners for Region XII.

RULING

The Supreme Court dismissed the petitions. The Court held that the COMELEC did not commit grave abuse of discretion. The legal logic rests on the constitutional and statutory framework granting the COMELEC broad powers as the sole judge of election contests and the administrator of election laws. The Court emphasized that it cannot review the COMELEC’s factual findings or substitute its own judgment on the weight of evidence, such as the statistical improbabilities or alleged irregularities raised by petitioners, absent a clear showing of arbitrariness.
The Court found that the COMELEC and the Board substantially complied with the guidelines set forth in the earlier case. Petitioners were given the opportunity to present their evidence and objections. The COMELEC’s determination that the evidence was insufficient to warrant the exclusion of the contested returns was an exercise of its adjudicatory discretion. The Court ruled that allegations of fraud must be proven with clear and convincing evidence, and the petitioners’ reliance on statistical anomalies and general claims, without specific and conclusive proof linking them to the preparation or tampering of the actual returns canvassed, was inadequate. The Court further noted that questions regarding the conduct of the election and the appreciation of evidence are generally beyond the scope of certiorari, as they involve factual determinations within the COMELEC’s exclusive jurisdiction. The petitions, therefore, failed to demonstrate the capricious or whimsical exercise of judgment necessary for a finding of grave abuse of discretion.