Saquilayan V. Comelec

Saquilayan v. COMELEC Facts: Saquilayan and Jaro were candidates for the Office of Municipal Mayor of Imus, Cavite. Saquilayan was proclaimed winner. Jaro instituted an Election Protest Case before the RTC, contesting the results of all 453 election precincts. He alleges the ff: 1. Votes in favor of Jaro were considered stray 2. Ballots and votes were misappreciated (considered null and void, or counted in favor of Saquilayan) 3. Votes that were void (containing stickers or markings) were counted in favor of Saquilayan, etc. Saquilayan filed a Motion to Dismiss, which was denied by the RTC. Questioning the denial of his Motion to Dismiss, the COMELEC (Division) ruled in favor of Saquilayan and ordered the dismissal of the election protest. It ruled that JARO’s allegations failed to state a cause of action, on the basis of Pena v. HRET. In Pena v. HRET, it was held that the bare allegations of massive fraud, widespread intimidation and terrorism, without specification and substantiation of where and how these occurrences took place, render the protest fatally defective. Upon reconsideration sought by Jaro, the COMELEC En Banc, Saquilayan’s Motion to Dismiss was again dismissed, and the Election Protest Case was ordered to proceed. Issue: Whether the COMELEC erred in denying Saquilayan’s MTD Held: No. The present case is similar to Miguel v. COMELEC, which the COMELEC En Banc used as basis in ordering the Election Protest Case to proceed. In both cases, the protestants questioned all the precincts in their respective municipalities. As Miguel v. COMELEC is more recent than Pena v. HRET (as used by the COMELEC Division) therefore, the former should prevail in case of a conflict. Furthermore, election contests involve public interest. Technicalities and procedural barriers should not be allowed to stand if they constituted an obstacle to the determination of the true will of the electorate. Laws governing election contests must be liberally construed to the end that the will of the people in the choice of public officials may not be defeated by mere technical objections. Allowing the election protest to proceed would be the best way of removing any doubt as to who was the real candidate chosen by the electorate.