**Sultan Usman Sarangani, Soraida M. Sarangani, and Hadji Nor Hassan v. Commission on Elections and Hadji Abolais R. Omar, Manan Osop, and Atty. Nasib D. Yassin**
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### Facts:
In September 1997, Hadji Oblais R. Omar, represented by Atty. Nasib Yasin, filed a petition with the Commission on Elections (COMELEC) to annul several precincts and voter books in Madalum, Lanao Del Sur, including the precinct in Barangay Padian Torogan. The COMELEC summoned the Board of Election Inspectors of the questioned precincts to respond. The incumbent mayor of Madalum, Usman T. Sarangani, alongside other barangay chairmen, filed opposition affidavits countering the petition.
Following hearings and submissions, on February 11, 1998, COMELEC referred the case to its Law Department for investigation. A memorandum was issued to Atty. Muslemin Tahir to conduct an inquiry. Tahir established a Task Force and conducted an ocular inspection on June 18, 1998, revealing that Barangay Padian Torogan contained only uninhabitable structures and was inaccurately reported to house 285 residents per the 1995 census.
Consequently, the Task Force reported back confirming the precincts as “ghost precincts.” On June 29, 1998, COMELEC officially declared Padian Torogan a “ghost precinct.” Former and incumbent local officials filed for certiorari and mandamus on November 3, 1998, against COMELEC’s order, alleging grave abuse of discretion, and requested consolidation with a similar case, which was denied.
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### Issues:
1. **Whether the COMELEC gravely abused its discretion in declaring Padian Torogan as a ghost precinct through the order dated June 29, 1998.**
2. **Whether such a declaration violated relevant provisions of the Omnibus Election Code.**
3. **Whether the annulment of the precinct improperly disenfranchised voters.**
4. **Whether the procedural lapses or irregularities impacted the legality of the COMELEC’s decision.**
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### Court’s Decision:
The Supreme Court reviewed the factual findings by COMELEC, supported by the Task Force’s investigation, concluding no abuse of discretion existed in the declaration of Padian Torogan as a ghost precinct.
#### Resolution of Each Issue:
1. **Grave Abuse of Discretion:** The court determined that COMELEC exerted proper efforts in investigating, resulting in the correct conclusion that no inhabitants resided in Padian Torogan, thus justifying the “ghost precinct” label.
2. **Violation of Omnibus Election Code:** The court emphasized that while every barangay must have at least one precinct, the existence of voters is paramount. The determination that no residents were found supports the legitimacy of the precinct annulment without violating the election code.
3. **Voter Disenfranchisement:** Ascertaining no real voters existed in Padian Torogan, the decision did not infringe on any individuals’ right to suffrage. The exclusion bolstered the integrity of the electoral process by eliminating fictitious votes.
4. **Procedural Issues:** The thorough investigation conducted by the COMELEC’s Task Force validated the procedural soundness of the resolution declaring the precinct a ghost precinct.
The court concluded that COMELEC did not demonstrate grave abuse, thus upholding the order.
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### Doctrine:
1. **Factual Determination by COMELEC:** The COMELEC’s factual findings, particularly on the existence of precincts and voters, are binding on the court absent substantial contrary evidence.
2. **Administrative Power and Investigations:** The COMELEC has broad administrative powers to investigate and ensure the integrity of precincts and voter registration.
3. **Non-Disenfranchisement Principle:** Voter lists comprising non-existent voters should be excluded to protect the sanctity of suffrage, aligning with constitutional guarantees.
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### Class Notes:
1. **Factual Findings of Administrative Agencies:** COMELEC’s factual determinations in election disputes hold significant weight and are generally conclusive unless proven otherwise.
2. **Unit of Territory for Voting:** Under the Omnibus Election Code, every barangay must have at least one precinct, barring nonexistent population circumstances.
3. **Administrative Powers of COMELEC:** The body possesses authority to conduct thorough investigations to ensure prudence in the election process and validity of voter registration.
4. **Safeguarding Electoral Integrity:** Measures that exclude fictitious precincts or voters enhance electoral integrity, preventing disenfranchisement.
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### Historical Background:
The context of this case lies in the persistent issues of electoral fraud in Lanao del Sur, infamously known for significant irregularities during previous election periods, including the Martial Law era. The investigation into ghost precincts reflects broader efforts to combat electoral fraud and maintain credible elections in areas historically plagued by voting irregularities.
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