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9/23/2020 G.R. No. 153945 Today is Wednesday, September 23, 2020 Constitution Statutes Executive Issuances Judicial Issuances Other Issuances Jurisprudence International Legal Resources AUSL Exclusive EN BANC G.R. No. 153945 February 4, 2003 REYNATO BAYTAN, REYNALDO BAYTAN and ADRIAN BAYTAN, petitioners, vs. THE COMMISSION ON ELECTIONS, respondent. DECISION CARPIO, J.: The Case Challenged in this petition for certiorari1 with prayer for temporary restraining order and preliminary injunction is the Resolution dated June 3, 20022 of the Commission on Elections ("COMELEC" for brevity) en banc in E.O. Case No. 97-503. In its assailed Resolution, the COMELEC en banc denied the motion to reconsider Minute Resolution No. 00-2281 dated November 9, 20003 ordering the Law Department to file criminal cases for "double registration" against petitioners Reynato Baytan, Reynaldo Baytan and Adrian Baytan ("petitioners" for brevity). The Antecedents On June 15, 1997, petitioners were on their way to register for the May 1998 elections when they met the newly elected Barangay Captain, Roberto Ignacio ("Ignacio" for brevity), in Barangay 18, Zone II of Cavite City. Ignacio led petitioners to register in Precinct No. 83-A of Barangay 18. Petitioners registered in this precinct as evidenced by Voters Registration Records Nos. 41762473, 41762472 and 41762470. When petitioners returned home, they wondered why the registrants in this precinct looked unfamiliar to them. This prompted petitioners to return to the registration center to study the precinct map of Barangay 18. They then realized that their residence is situated within the jurisdiction of Barangay 28. Thus, petitioners proceeded to Precinct 129-A of Barangay 28 and registered anew on June 22, 1997 as evidenced by Voters Registration Records Nos. 42662969, 42662968 and 42662917. Subsequently, petitioners sent a letter dated August 21, 1997 to former COMELEC Assistant Executive Director Jose Pio O. Joson and furnished a copy thereof to COMELEC Registrar Francisco Trias. In this letter, petitioners requested for advice on how to cancel their previous registration. They also explained the reason and circumstances of their second registration and expressed their intention to redress the error. On September 16, 1997, the Election Officer of Cavite City forwarded copies of petitioners’ Voters Registration Records to the Provincial Election Supervisor, Atty. Juanito V. Ravanzo ("Ravanzo" for brevity), for evaluation. Ravanzo endorsed the matter to the Regional Director for prosecution. Eventually, the Law Department endorsed the case to Ravanzo for resolution. On January 10, 1998, Ravanzo recommended filing an information for double registration against petitioners. In an en banc meeting held on November 09, 2000, the COMELEC in its Minute Resolution No. 00-2281 affirmed the recommendation of Ravanzo. Petitioners moved for reconsideration. The COMELEC en banc denied the motion and disposed as follows: https://lawphil.net/judjuris/juri2003/feb2003/gr_153945_2003.html 1/7

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Baytan v. Commission on Elections

Judgment

Question Presented: Whether petitioner's voluntary disclosure and alleged good faith mistake is sufficient to survive a preliminary hearing requiring only probable cause?

Alleged Acts: The petitioner in the case were residents of the jurisdiction of Barangay 28, however, when the petitioners initially went to vote they were directed by newly elected Barangay Captain, Roberto Ignacio, to vote in Barangay 18. The petitioners voted in Barangay 18, but when they realized the mistake, went ahead and voted in Barangay 28 and sent a letter to Election Commission requesting advice on how to cancel the previous registration and indicated the circumstances under which they voted in Barangay 18. The letter was then forwarded to the Election Supervising Attorney for evaluation and prosecution was recommended.

Procedural history: The recommendation was then affirmed by the Election Commission, the petitioner moved for reconsideration, and the Election Commission denied the motion. The petitioners allege that they had no intention of committing an election offense and the letter could be deemed substantial compliance with election laws.

Summary: The court determined that the preliminary investigation required solely probable cause to hold the petitioners for trial for the offense of double registration. In light of the petitioner’s letter, multiple inconsistencies in statements, and the lack of an intent element to the registration laws, the court determined that probable cause was satisfied.

Conclusion: The court dismissed the petition for lack of merit.

Legal Issue(s)

Civil Procedure
Voter Registration

Region: Asia-Pacific

Country: Phillippines

Language of Decision

English

Court: Supreme Court

Election Type: Review of law

Date of decision: Feb 4, 2003

Geolocation

Latitude: 14.580014966278988

Longitude: 120.86501197177809

: Geolocation

Primary Documents

Baytan v. Commission on Elections.pdf
english
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