Facts:
On May 14, 1984, elections were held in Pampanga for the Batasan Pambansa. The Provincial Board of Canvassers began canvassing the election returns that evening. Both the KBL and the UNIDO political parties were represented during the canvass. The canvassing was completed by 11:30 PM on May 16, 1984, without any objections raised. On May 17, 1984, at 12:50 AM, Bren Z. Guiao submitted written objections to the inclusion of returns from 31 voting centers, citing various irregularities. Despite the late submission, the Board set a hearing for 11:30 AM on the same day. The Board asked the COMELEC for permission to proclaim the winning candidates without prejudice to the objections. COMELEC granted this request, and the Board dismissed Guiao’s objections due to lack of evidence and issued the proclamation at 6:00 PM on May 17, 1984.
Guiao filed an urgent petition with COMELEC on May 18, 1984, seeking to restrain the Board from proceeding further and to annul the proceedings. On May 22, 1984, he filed another petition to annul Canlas’ proclamation. The First Division of the COMELEC dismissed Guiao’s suit but allowed him to file an election protest.
Guiao appealed to the COMELEC en banc, but his motion was denied on July 18, 1984. He then filed a petition with the Supreme Court on July 24, 1984, seeking a preliminary injunction to stop the COMELEC hearing set for July 25, 1984. A supplemental petition was filed on July 25, 1984. However, on August 4, 1984, the COMELEC en banc upheld the proclamation of Canlas by a vote of 6-1, with Commissioner Felipe dissenting.
Issues:
1. Whether the written objections filed by Guiao were timely and should have been considered by the Provincial Board of Canvassers.
2. Whether the proclamation of Aber Canlas was valid given the objections raised.
3. Whether COMELEC’s actions in authorizing the proclamation and dismissing Guiao’s objections were lawful and procedural.
4. Whether Section 54 of Batas Pambansa Blg. 697 was properly interpreted and applied by the COMELEC and the Provincial Board of Canvassers.
5. Whether the procedural and administrative conduct by the Board, specifically the replacement of its chairman, affected the legality of Canlas’ proclamation.
Court’s Decision:
1. Timeliness of Written Objections:
– The Court ruled that objections must be filed during the canvassing proper (second stage), before the votes are tallied (third stage), as per Section 54 of Batas Pambansa Blg. 697. Guiao’s objections were filed too late, after the canvass was completed. Therefore, his objections were considered untimely.
2. Legitimacy of Canlas’ Proclamation:
– The proclamation of Canlas was upheld as the written objections were not timely. The Board had the authority and the proclamation was done in accordance with the COMELEC’s previous authorization, despite the objections being handled summarily.
3. Legitimacy of COMELEC’s Actions:
– COMELEC’s actions, including the granting of authority to proclaim the winning candidates and dismissing Guiao’s objections for lack of evidence, were found to be consistent with electoral laws and procedures. The solicitation of authority from COMELEC by the Board was a discretionary action to avoid undue proclamation delays.
4. Section 54 Interpretation:
– The Supreme Court agreed with COMELEC’s interpretation that written objections must be filed during the actual canvassing of the election returns. Once votes are tallied, no new objections should delay the proclamation process. Thus, Section 54 was correctly interpreted and applied.
5. Procedural Conduct:
– The Court found no procedural irregularities in the replacement of the Chairman of the Board of Canvassers. The arrangement was properly authorized to manage local logistical challenges, given the provincial election officer’s concurrent responsibilities.
Doctrine:
– Pre-proclamation controversies must be resolved timely and objections need to be filed during the canvassing (second stage) to prevent unnecessary delays in the proclamation process.
– Written objections filed after canvassing but before proclamation are not considered timely under Section 54 of Batas Pambansa Blg. 697.
– Administrative and procedural matters, such as the appointment of the chairman of the canvassing board, if based on sound logistical needs and properly authorized, do not impair the legality of the proceedings.
Class Notes:
– Key concepts: pre-proclamation controversy, canvassing of election returns, timely submission of objections, ministerial duty of canvassing board, procedural due process of law.
– Legal provision: Section 54 of Batas Pambansa Blg. 697 – written objections must be filed during the canvassing stage, and the proclamation must be deferred until objections are resolved.
Historical Background:
The case reflects the political climate of the Philippines during the 1984 Batasan Pambansa elections, marked by intense competition between opposition and ruling party candidates. It exemplifies the Philippine electoral framework’s adherence to procedural rigor in pre-proclamation controversies, which is crucial to upholding electoral integrity during politically charged periods.
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