G.R. No. L-69765-67, L-69773-75, and L-69846 November 19, 1985
MAHADI M. PIMPING, et al., petitioners, vs. COMMISSION ON ELECTIONS, et al., respondents.

FACTS

These consolidated petitions arose from the local elections in Marawi City on January 30, 1980. Petitioners were KBL candidates for various city positions, while private respondents were their NP rivals. Multiple election protests were filed with the COMELEC. On January 7, 1985, the COMELEC issued a joint resolution deciding the protests in favor of the private respondents, declaring them the duly elected officials. The COMELEC, in its Order of January 29, 1985, denied the petitioners’ motions for reconsideration, declared its January 7 resolution final and executory, and barred further motions. Petitioners filed these certiorari petitions, alleging grave abuse of discretion. They also sought a temporary restraining order to prevent the private respondents from assuming office. However, respondents manifested that the COMELEC resolution had already been executed, making the assumption of office by the winning candidates a fait accompli.
The petitioners challenged the COMELEC’s resolution on several grounds, including the alleged erroneous appreciation of ballots and exclusion of election returns. They also contended that the promulgation of the resolution violated due process, as they were not given proper notice, learning of the adverse decision only through newspapers. They argued that Section 23 of COMELEC Resolution No. 1450, which made its decisions final and executory after ten days, was unconstitutional for contradicting the constitutional provision allowing a thirty-day period to appeal COMELEC decisions to the Supreme Court.

ISSUE

Whether the COMELEC committed grave abuse of discretion in issuing its January 7, 1985 Resolution and January 29, 1985 Order, warranting the Supreme Court’s intervention through certiorari.

RULING

The Supreme Court dismissed the petitions. The Court held that the COMELEC did not commit grave abuse of discretion amounting to lack or excess of jurisdiction. The Court emphasized that in election cases, the COMELEC’s factual findings, especially concerning the appreciation of ballots, are generally binding and conclusive upon the Supreme Court, provided they are supported by substantial evidence. The petitioners’ arguments essentially questioned the COMELEC’s judgment on the merits of the election protests, which involved the correctness of its conclusions rather than its jurisdiction. The Court found no showing that the COMELEC’s appreciation of the contested ballots was arbitrary or devoid of rational basis.
Regarding procedural issues, the Court ruled that the petitioners were not denied due process. They were able to file motions for reconsideration, which the COMELEC duly considered and denied. The claim of lack of notice for the promulgation was not substantiated to have prejudiced their substantial rights. On the constitutional challenge, the Court found it unnecessary to rule on the validity of the COMELEC rule, as the petitions were being resolved on other grounds. Furthermore, the Court noted that the execution of the COMELEC resolution had rendered the plea for a restraining order moot and academic. The Court concluded that no jurisdictional infirmity or error of law attended the proceedings, and the COMELEC acted within its constitutional mandate as the sole judge of election contests involving elective city officials.