Facts:
This case revolves around the 1965 national elections for the office of Representative in the second congressional district of Ilocos Sur, where Lucas V. Cauton, Pablo Sanidad, and Godofredo S. Reyes were contenders. During the canvassing of votes by the Provincial Board of Canvassers of Ilocos Sur, discrepancies in the vote counts presented by the Provincial Treasurer and those held by the Liberal Party were noticed in the precincts of Candon, Santiago, and Sta. Cruz. Sanidad petitioned the Commission on Elections (COMELEC) to retrieve the election returns from ballot boxes in these precincts to verify the vote counts, leading to a restraining order against the proclamation of a winner and subsequent hearing. The investigation found uniform alterations in the vote entries across the municipalities concerned, but efforts to verify were hindered by the non-compliance of municipal treasurers of Candon and Santiago to the subpoena issued by COMELEC. Consequently, on December 22, 1965, COMELEC allowed the opening of ballot boxes to retrieve the mentioned election returns. In response, Cauton petitioned the Supreme Court to annul COMELEC’s resolution on grounds of jurisdictional overreach. Despite the issuance of preliminary injunction, COMELEC proceeded with the December 28, 1965, hearing for the examination and recording of the election returns’ contents. Parallelly, Sanidad initiated a recount petition in the Ilocos Sur Court of First Instance. Cauton also requested the Supreme Court to enjoin this recount process, albeit unsuccessfully.
Issues:
1. Whether COMELEC had the jurisdiction to order the opening of ballot boxes for the purpose of retrieving election returns for verifications.
2. Whether the alteration in vote counts constituted a violation of election laws that warranted the intervention of COMELEC.
Court’s Decision:
The Supreme Court dismissed Cauton’s petition, upholding COMELEC’s resolution as within its constitutional and legal jurisdiction. It established that COMELEC’s authority encompasses managing and ensuring the integrity of election processes, including the investigation of anomalies that might indicate election law violations. The Court held that the retrieval of election returns from ballot boxes was a valid exercise of COMELEC’s administrative and supervisory powers, aimed not at aiding any party’s electoral victory but at ensuring a fair and honest canvass of votes.
Doctrine:
The ruling reiterates the doctrine that COMELEC has broad administrative and supervisory authority over elections, encompassing the capability to investigate vote count discrepancies to ensure the integrity of election results. It confirms COMELEC’s mandate to administer and enforce election laws, including taking necessary steps to address and rectify anomalies affecting election outcomes.
Class Notes:
1. Administrative and Supervisory Authority of COMELEC: COMELEC is vested with the power to enforce and administer all laws related to the conduct of elections.
2. Resolution of Election Discrepancies: COMELEC may order the retrieval of election returns from ballot boxes to resolve discrepancies between different copies of election returns, thereby ensuring the canvass of votes reflects the true expression of the voters’ will.
Historical Background:
The 1965 national elections in the Philippines were marked by this significant legal dispute, highlighting issues of electoral integrity and the procedural mechanisms to address them. The case underscores the crucial role of COMELEC in safeguarding democratic processes and delineates the scope of its powers in managing election-related controversies.
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