Malaluan v. Comelec

G.R. No. 120193 (March 6, 1996)

SC ruled Malaluán's appeal moot; damages claim requires legal basis at the time.

Facts:

The case involves an election contest for the position of Municipal Mayor of Kidapawan, North Cotabato, between Luis Malaluan (petitioner) and Joseph Evangelista (respondent). In the synchronized national and local elections held on May 11, 1992, Evangelista was proclaimed the winner by the Municipal Board of Canvassers, having received 10,498 votes against Malaluan's 9,792 votes, resulting in a margin of 706 votes.

On May 22, 1992, Malaluan filed an election protest with the Regional Trial Court (RTC), contesting results from 64 out of 181 precincts. The RTC ruled in favor of Malaluan, declaring him the duly elected mayor with a plurality of 154 votes. The RTC also ordered Evangelista to pay Malaluan for protest expenses, moral and exemplary damages, and attorney's fees. Evangelista appealed this decision to the Commission on Elections (COMELEC) on February 3, 1994.

On February 4, 1994, Malaluan filed a motion for execution pending appeal, which the RTC granted, allowing him to assume the office of Municipal Mayor. However, the COMELEC later reversed the RTC's decision, declaring Evangelista the rightful winner and ordering Malaluan to vacate the office.

Malaluan's petition for certiorari and prohibition was filed on May 31, 1995, after the COMELEC denied his motion for reconsideration. By this time, the term of office for the local officials elected in May 1992 had expired on June 30, 1995, rendering the contest moot and academic regarding the right to the mayoralty seat.

Despite the mootness of the election contest, the COMELEC had awarded damages to Evangelista, which included attorney's fees, actual expenses for xerox copies, unearned salary, and other emoluments from March 1994 to April 1995, totaling P557,110.00. Malaluan contested the legality of this award, arguing that the damages were not properly alleged or proven during the trial.

Legal Issues:

  1. Whether the COMELEC gravely abused its discretion in awarding damages to Evangelista despite the mootness of the election contest.
  2. Whether the award of actual damages, including attorney's fees and unearned salary, was legally justified under the circumstances of the case.

Arguments:

  • Petitioner (Malaluan):

    • Contended that the COMELEC's award of damages was improper and lacked legal basis, as the damages were not alleged or proven during the trial.
    • Argued that the election protest was not clearly unfounded and that the trial court's decision should not be penalized due to alleged errors.
    • Asserted that he was not a usurper, as he assumed office under color of right based on the RTC's decision.

  • Respondent (Evangelista):

    • Argued that the election protest filed by Malaluan was clearly unfounded and filed in bad faith, justifying the award of damages.
    • Claimed that the execution of judgment pending appeal was issued with grave abuse of discretion, leading to his wrongful ouster and entitlement to damages.

Court's Decision and Legal Reasoning:

The Supreme Court granted Malaluan's petition, affirming that while the COMELEC's decision declaring Evangelista the winner was upheld, the portion awarding damages was declared null and void due to grave abuse of discretion. The Court reasoned that:

  • The election contest had become moot and academic due to the expiration of the term of office, and thus, the right to the mayoralty seat was no longer at issue.
  • The COMELEC's award of damages lacked a legal basis, as there was no breach of contract, tortious act, or specific legal provision justifying the monetary claims.
  • The Court emphasized that the mere filing of an election protest does not automatically imply bad faith or malicious intent, and the trial court's decision should not be penalized for its errors without clear proof of wrongdoing.
  • The Court reiterated that an elective official who has been proclaimed as the winner and has assumed office is entitled to compensation for services rendered, unless proven otherwise.

Significant Legal Principles Established:

  1. The expiration of the term of office in an election contest renders the case moot and academic concerning the right to the contested office.
  2. Actual or compensatory damages in election cases must be grounded in a breach of obligation, tortious act, or a specific legal provision; mere claims for expenses without such basis are insufficient.
  3. The presumption of regularity in the performance of official duties applies to judicial decisions, and errors in judgment do not automatically equate to bad faith or malicious intent.