Case Digest: Rulloda vs. Comelec

G.R. No. 154198            January 20, 2003

PETRONILA S. RULLODA vs. COMELEC and REMEGIO PLACIDO

Facts:

Comelec denied petitioner’s request to substitute her deceased husband in the Barangay Chairman Candidacy despite the fact that petitioner apparently garnered the highest votes when constituents wrote her name in the ballots. Respondents cited resolution 4801 and Section 7 of the Omnibus Election Code which prohibits substitution of candidates. Private respondent Placido contended that it was only right that he be proclaimed winner since he was the only one who filed a certificate of candidacy and, hence, the only candidate running.

Issue:

Whether or not there was grave abuse of discretion when Comelec denied petitioner’s request that she be allowed to run for elections.

Ruling:

There being no specific provision governing substitution of candidates in barangay elections, a prohibition against said substitution cannot be said to exist.

Petitioner’s letter-request was considered a certificate of candidacy when COMELEC issued its resolution denying the same. In the contested election, it was petitioner who obtained the plurality of votes. Technicalities and procedural niceties in election cases should not be made to stand in the way 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.

Categories: 2003, Election Case, G.R. No. 154198, January 20, Rulloda vs. Comelec, Substitution of Candidates