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.
