[G.R. No. 199149, January 22, 2013]
LIWAYWAY VINZONS-CHATO, Petitioner, v. HOUSE OF REPRESENTATIVES ELECTORAL TRIBUNAL AND ELMER E. PANOTES, RESPONDENTS.
[G.R. NO. 201350]
ELMER E. PANOTES, Petitioner, v. HOUSE OF REPRESENTATIVES ELECTORAL TRIBUNAL AND LIWAYWAY VINZONS-CHATO, Respondents.
D E C I S I O N
Municipality No. of votes for Panotes No. of votes for Chato Daet 18,085 15,911 Vinzons 8,107 6,713 Basud 7,879 6,527 Mercedes 7,739 9,333 Talisay 5,015 4,190 San Vicente 2,359 2,453 San Lorenzo 2,520 2,695
Votes for Chato Votes for Panotes Per
6 166 183 17 268 164 -104 7 119 134
206 85 -121 8 70 81 11 239 133 -106 15 87 105 18 193 100 -93 19 148 191 43 239 138 -101 25 233 261 28 399 251 -148 27 263 287 24 366 214 -152
Votes for Chato Votes for Panotes Per
2 269 295 26 354 157 -197 7 243 275 32 363 2 -361 17 183 202 19 269 36 -233 23 281 318 37 440 334 -106 24 223 261 38 341 227 -114 25 202 229 27 391 343 -48 31 258 284 26 407 305 -102 32 243 267 24 521 511 -10 40 259 293 34 373 96 -277 41 226 260 34 348 54 -294 44 294 313 19 404 357 -47 56 287 309 22 399 320 -79 60 153 182 29 252 77 -175
Outer condition:a. The top cover of the ballot box is loose and can be lifted, so the election documents - e.g. ballots, minutes of voting, election returns - can be taken out.cralawlibrary
b. In some ballot boxes, when the key was inserted into the padlock, the upper portion of the lock disconnected from its body, which means that the lock had been previously tampered with.cralawlibrary
c. In the municipalities where Petitioner (Panotes) was able to seal the ballot boxes with packing tape, this tape seal was broken/cut/sliced, which means that the ballot boxes had been opened prior to the initial revision.cralawlibrary
d. Some of the self-locking security seal was not properly attached.
Inner condition:a. The contents of the ballot box - e.g. ballots and the documents - were in total disarray, which means that it was tampered with.cralawlibrary
b. Some of the Minutes of Voting and Election Returns were MISSING and only the ballots were found inside the ballot box.cralawlibrary
c. The ballots were unnecessarily folded and/or crumpled in the clustered precincts where the votes of (Panotes) were substantially reduced.
(d) When it has been shown, in a preliminary hearing set by the parties or by the Tribunal, that the integrity of the ballots and ballot boxes used in the May 10, 2010 elections was not preserved, as when there is proof of tampering or substitutions, the Tribunal shall direct the printing of the picture images of the ballots of the subject precinct stored in the data storage device for the same precinct. The Tribunal shall provide a non- partisan technical person who shall conduct the necessary authentication process to ensure that the data or image stored is genuine and not a substitute. It is only upon such determination that the printed picture image can be used for the revision, (as amended per Resolution of February 10, 2011).
Yes, I requested the presence of the other two members because the information that I gathered would be that there was a time log of about six hours where you would stop the canvassing, and the information that we got from our lawyers there was that there were certain cards that had no memory and had to be reconfigured from some precincts, and that, in the meantime, you stopped the canvassing and resumed after six hours.
ATTY. ROMERO-CORTEZ: This is what happened. Because of the municipalities of Labo, Vinzons, and Basud, there were CF cards that had to be replaced because they were defective. REP. VINZONS-CHATO: But, that was after the voting had closed, right? The voting had closed and those cards were defective and you had to replace them. ATTY. ROMERO-CORTEZ: To my recollection, Your Honor, that was during May 10.13Ï‚rÎ½l1
Sec. 1. Original of an electronic document. â€“ An electronic document shall be regarded as the equivalent of an original document under the Best Evidence Rule if it is a printout or output readable by sight or other means, shown to reflect the data accurately.cralawlibrary
Sec. 2. Copies as equivalent of the originals. - When a document is in two or more copies executed at or about the same time with identical contents, or is a counterpart produced by the same impression as the original, or from the same matrix, or by mechanical or electronic re- recording, or by chemical reproduction, or by other equivalent techniques which accurately reproduces the original, such copies or duplicates shall be regarded as the equivalent of the original.cralawlibrary
Notwithstanding the foregoing, copies or duplicates shall not be admissible to the same extent as the original if:
(a) a genuine question is raised as to the authenticity of the original; or (b) in the circumstances it would be unjust or inequitable to admit the copy in lieu of the original.
x x x (T)he votes determined after the revision in the 20 precincts in Basud and Daet, which yielded reversal of votes, cannot be relied upon, as they do not reflect the true will of the electorate. Hence, the Tribunal has to rely on what is reflected in the election returns and/or statement of votes by precinct the same being the best evidence of the results of the election in said precincts in lieu of the altered ballots.
THE HON. PUBLIC RESPONDENT HRET IN RESOLUTION NO. 11-321 (DATED 08 JUNE 2011) REGARDED THE PICTURE IMAGES OF THE BALLOTS AS THE EQUIVALENT OF THE ORIGINAL, AND USED THE PICTURE IMAGES OF THE BALLOTS IN ITS SUBSEQUENT RESOLUTION NO. 11-487 (DATED 15 SEPTEMBER 2011) - DESPITE THE FACT THAT UNDER REPUBLIC ACT NO. 9369 THE PICTURE IMAGES OF THE BALLOTS ARE NOT THE "OFFICIAL BALLOTS" SINCE THE AUTOMATED ELECTION SYSTEM (AES) USED DURING THE MAY 2010 ELECTIONS WAS PAPER BASED.cralawlibrary
THE HON. PUBLIC RESPONDENT HRET IN RESOLUTION NO. 11-321 (DATED 08 JUNE 2011) REGARDED THE PICTURE IMAGES OF THE BALLOTS AS THE EQUIVALENT OF THE ORIGINAL, AND USED THE PICTURE IMAGES OF THE BALLOTS IN ITS SUBSEQUENT RESOLUTION NO. 11-487 (DATED 15 SEPTEMBER 2011) - EVEN IF THE PICTURE IMAGES OF THE BALLOTS CANNOT BE REGARDED AS THE EQUIVALENT OF THE ORIGINAL PAPER BALLOTS UNDER THE RULES ON ELECTRONIC EVIDENCE. IN THE FIRST PLACE, THE RULES ON ELECTRONIC EVIDENCE DO NOT EVEN APPLY TO THE PICTURE IMAGES OF THE BALLOTS.cralawlibrary
THE HON. PUBLIC RESPONDENT HRET IN RESOLUTION NO. 11-321 (DATED 08 JUNE 2011) REGARDED THE PICTURE IMAGES OF THE BALLOTS AS THE EQUIVALENT OF THE ORIGINAL, AND USED THE PICTURE IMAGES OF THE BALLOTS IN ITS SUBSEQUENT RESOLUTION NO. 11-487 (DATED 15 SEPTEMBER 2011) - EVEN IF UNDER THE ELECTRONIC COMMERCE ACT OF 2000, THE PICTURE IMAGES OF THE PAPER BALLOTS ARE NOT THE EQUIVALENT OF THE ORIGINAL PAPER BALLOTS.cralawlibrary
THE HON. PUBLIC RESPONDENT HRET IN RESOLUTION NO. 11-
321 (DATED 08 JUNE 2011) REGARDED THE PICTURE IMAGES OF THE BALLOTS AS THE EQUIVALENT OF THE ORIGINAL, AND USED THE PICTURE IMAGES OF THE BALLOTS IN ITS SUBSEQUENT RESOLUTION NO. 11-487 (DATED 15 SEPTEMBER 2011) - EVEN IF PETITIONER HAS SHOWN BY SUBSTANTIAL EVIDENCE THAT THE CF CARDS USED IN THE MAY 2010 ELECTIONS WERE NOT PRESERVED OR WERE VIOLATED.cralawlibrary
THE HON. PUBLIC RESPONDENT HRET IN RESOLUTION NO. 11-321 (DATED 08 JUNE 2011) REGARDED THE PICTURE IMAGES OF THE BALLOTS AS THE EQUIVALENT OF THE ORIGINAL, AND USED THE PICTURE IMAGES OF THE BALLOTS IN ITS SUBSEQUENT RESOLUTION NO. 11-487 (DATED 15 SEPTEMBER 2011) - EVEN IF THERE IS NO LEGAL BASIS FOR THE HONORABLE TRIBUNAL TO CONSIDER THE PICTURE IMAGE OF THE BALLOTS AS EVIDENCE, SINCE SUCH PICTURE IMAGES ARE NOT EVEN RECOGNIZED AND THEIR APPRECIATION ARE NOT PROVIDED FOR, UNDER THE OMNIBUS ELECTION CODE.cralawlibrary
THE HON. PUBLIC RESPONDENT HRET ISSUED RESOLUTION NO. 11-487 (DATED 15 SEPTEMBER 2011) DESPITE THE PENDENCY OF THE COMELEC INVESTIGATION ON THE MAIN CF CARD FOR CLUSTERED PRECINCT 44 OF THE MUNICIPALITY OF DAET.cralawlibrary
THE HON. PUBLIC RESPONDENT HRET ISSUED RESOLUTION NO. 11-487 (DATED 15 SEPTEMBER 2011) BASED ON VILLAFUERTE VS. JACOB (15 HRET REPORT 754), WHICH IS ONLY AN HRET CASE WHICH HAS NO PRECEDENTIAL VALUE.cralawlibrary
THE HON. PUBLIC RESPONDENT HRET ISSUED RESOLUTION NO. 11-321 (DATED 08 JUNE 2011) AND RESOLUTION NO. 11-487 (DATED 15 SEPTEMBER 2011) - IN CONTRAVENTION OF CASE LAW THAT THERE SHOULD BE A FULL BLOWN TRIAL CONCERNING THE INTEGRITY OF THE BALLOTS.21Ï‚rÎ½l1
1.THE HONORABLE TRIBUNAL ALREADY CATEGORICALLY RULED IN ITS OWN RESOLUTION NO. 11-487 THAT THE VOTES DETERMINED IN THE REVISION CANNOT BE RELIED UPON SINCE THEY ARE THE PRODUCT OF ALTERED BALLOTS;
2.THE ISSUES RESOLVED IN RESOLUTION NO. 11-487 DATED SEPTEMBER 8, 2011 AND THOSE IN RESOLUTION NO. 12-079 DATED MARCH 22, 2012 ARE INTERRELATED;
3.PURSUANT TO THE RULING OF THIS MOST HONORABLE COURT IN THE CASE OF VARIAS VS. COMELEC (G.R. NO. 189078 FEBRUARY 11, 2010), THE RESULTS OF THE REVISION OF QUESTIONABLE BALLOTS CANNOT PREVAIL OVER ELECTION RETURNS;
4.THE PICTURE IMAGE OF THE BALLOTS MAY BE USED AS PROOF OF THE INTEGRITY OF THE PAPER BALLOTS;
5.RESOLUTION NO. 12-079 HAS NO LEGAL AND FACTUAL BASES TO STAND ON BECAUSE PRIVATE RESPONDENT FAILED TO ESTABLISH THE MERIT OR LEGITIMARY [sic] OF HER PROTEST CONSIDERING THAT SHE FAILED TO MAKE A REASONABLE RECOVERY OR MUCH LESS, ANY RECOVERY AT ALL;
6.RESOLUTION NO. 12-079 IS CONTRADICTORY TO THE FINDINGS OF THE PUBLIC RESPONDENT HRET IN ITS RESOLUTION NO. 11-487;
7.THE PENDENCY OF THE PETITION FOR CERTIORARI FILED BY PRIVATE RESPONDENT BEFORE THE SUPREME COURT IS A PRELIMINARY MATTER THAT MUST BE RESOLVED FIRST BEFORE THE HONORABLE TRIBUNAL MAY ORDER THE REVISION OF THE REMAINING 75% OF THE PROTESTED PRECINCTS;
8.THE RELIABILITY OF THE COMPACT FLASH CARDS HAS NOT BEEN SHOWN TO BE QUESTIONABLE;
9.THE RESULT OF THE RECOUNT CANNOT BE USED TO OVERTURN THE RESULTS AS REFLECTED IN THE ELECTION RETURNS BECAUSE THE BALLOTS IN EP CASE NO. 10-040 HAVE BEEN TAMPERED.29Ï‚rÎ½l1
Sec.15. Official Ballot. - x x x
x x x x
With respect to a paper-based election system, the official ballots shall be printed by the National Printing Office and/or the Bangko Sentral ng Pilipinas at the price comparable with that of private printers under proper security measures which the Commission shall adopt. The Commission may contact the services of private printers upon certification by the National Printing Office/Bangko Sentral ng Pilipinas that it cannot meet the printing requirements. Accredited political parties and deputized citizen's arms of the Commission shall assign watchers in the printing, storage and distribution of official ballots.cralawlibrary
x x x x
Sec. 11. Printing of the picture images of the ballots in lieu of photocopying. â€“ Unless it has been shown, in a preliminary hearing set by the parties or motu propio, that the integrity of any of the Compact Flash (CF) Cards used in the May 10, 2010 elections was not preserved or the same was violated, as when there is proof of tampering or substitution, the Tribunal, in lieu of photocopying of ballots upon any motion of any of the parties, shall direct the printing of the picture image of the ballots of the subject precinct stored in the data storage device for the same precinct. The Tribunal shall provide a non-partisan technical person who shall conduct the necessary authentication process to ensure that the data or image stored is genuine and not a substitute.
REYNANTE B. MAGO:
Q: Do you have any knowledge regarding the municipalities of Basud and Daet?
A: Wala po kasi hindi naman yung ang aking bet [sic, should have been "beatâ€, a journalistic jargon for the reporter's official place of assignment]
Q: Wala kang nalalaman regarding the municipalities of Basud and Daet?
A: Wala po.cralawlibrary
Q: Are you sure?
A: Sure na sure po kasi hindi ko naman po yun bet [sic] noong mga panahon na yun. Wala po akong direct na knowledge o participation regarding that during the time of election period.cralawlibrary
PROVINCIAL PROSECUTOR OSCAR J. VILAFUERTE:
Q: Before proceeding with your testimony, I would ask if you have any knowledge about the election regarding the municipalities of Basud and Daet?
A: Well, as the Vice-Chairman of the Provincial Board of Canvassers, Your Honor, in the last May 10, 2010 elections, yes.cralawlibrary
Q: Regarding the last CF cards?
A: No. We are just limited to the reception of the election results.cralawlibrary
Q: So, with regard to the CF cards in the municipalities of Basud and Daet, you do not have any knowledge at all?
A: Personally, no, because it does not affect us, Your Honor.cralawlibrary
MR. ANGEL S. AVERIA, JR:
Q: Will you be testifying regarding CF cards involving the municipalities of Daet and Basud?
A: Not specific to those municipalities.cralawlibrary
Q: Sa Daet, wala?
Q: Sa Basud, wala?
A: Wala ho. The reports I wrote for CENPEG is on a national scale.
x x x [O]n November 2, 2011, John Rex C. Laudiangco of the COMELEC Law Department, filed Comelec's Compliance with Manifestation and Motion to Admit the Attached Fact-Finding Investigation Report explaining the delay in the conduct of the investigation which was duly conducted on October 7, 2011, and submitting therewith a comprehensive Fact-Finding Investigation Report on the said investigation which was docketed in the Law Department as Case No. FF.INV. (LD) 11-46 entitled "In the Matter of Investigation on What Happened to the Main CF (Compact Flash) card for Clustered Precinct No. 44 for the Municipality of Daet, Camarines Norte.â€
In sum, the investigation revealed that the main CF Card for CP No. 44 of the Municipality of Daet could possibly be located inside the ballot box of the Municipal Board of Canvassers (MBOC) of Daet, Camarines Norte (serial no. CE-07-166991), after having been allegedly submitted in an improvised envelope, by the Board of Election Inspectors (BEI) of said CP 44 to the MBOC. It was, therefore, recommended that said ballot box be opened to retrieve the said CF card.cralawlibrary
Accordingly, in her January 6, 2012 letter to public respondent, Atty. Anne A. Romero-Cortez submitted certain documents relative to the opening of the ballot box of the MBOC of Daet, Camarines Norte (serial no. CE-07-166991) so the main CF Card for CP 44 of Daet may be retrieved and its custody turned over to the Election Records and Statistics Department (ERSD), COMELEC.cralawlibrary
Likewise, in her January 6, 2012 letter to public respondent, ERSD Director Ester L. Villaflor-Roxas requested that a representative from public respondent be present on the day to witness the verification and backing-up of the contents of the main CF card for CP No. 44 of Daet, Camarines Norte.cralawlibrary
Verily, the case of the alleged missing CF Card for Clustered Precinct No. 44 is no mystery at all.
Rule 7. Exclusive Control of Functions. - The Tribunal shall have exclusive control, direction, and supervision of all matters pertaining to its own functions and operation.
Rule 37. Post-Revision Determination of the Merit or Legitimacy of Protest Prior to Revision of Counter-Protest; Pilot Precincts; Initial Revision. - Any provision of these Rules to the contrary notwithstanding, as soon as the issues in any contest before the Tribunal have been joined, the Protestant, in case the protest involves more than 50% of the total number of precincts in the district, shall be required to state and designate in writing within a fixed period at most twenty five (25%) percent of the total number of precincts involved in the protest which said party deems as best exemplifying or demonstrating the electoral irregularities or fraud pleaded by him; and the revision of the ballots or the examination, verification or re-tabulation of election returns and/or reception of evidence shall begin with such pilot precincts designated. Otherwise, the revision of ballots or the examination, verification and re-tabulation of election returns and/or reception of evidence shall begin with all the protested precincts. The revision of ballots or the examination, verification and re-tabulation of election returns in the counter-protested precincts shall not be commenced until the Tribunal shall have determined through appreciation of ballots or election documents and/or reception of evidence, which reception shall not exceed ten (10) days, the merit or legitimacy of the protest, relative to the pilot protested precincts. Based on the results of such post-revision determination, the Tribunal may dismiss the protest without further proceedings, if and when no reasonable recovery was established from the pilot protested precincts, or proceed with the revision of the ballots or the examination, verification and re-tabulation of election returns in the remaining contested precincts.
The evidence as presented by the parties involving the twenty-five percent (25%) pilot protested clustered precincts is still insufficient to justify an indubitable conclusion. There are still material issues that should be taken into account. The substantial increase in the number of ballots for protestant and the substantial decrease in the number of ballots for protestee after comparing the election returns with the physical counts of the ballots are prima facie findings that should not be trivialized. Also, the reliability of the compact flash cards including its admissibility was raised by the protestant as an area of concern which needs precise and definitive ruling by the Tribunal. A complete disavowal of the constitutional duty will be debased if the Tribunal is not going to see the whole picture of the controversy. After all, the revision proceedings will not unduly toll the precious time of the Tribunal. All of the ballot boxes involved in this protest are already in the custody of the Tribunal and will not require sizeable manpower to revise it.
1Ï‚rÎ½l1 Roque, Jr. v. Commission on Elections, G.R. No. 188456, September 10, 2009, 599 SCRA 69, 151.cralawlibrary
2Ï‚rÎ½l1 AN ACT AMENDING REPUBLIC ACT NO. 8436, ENTITLED "AN ACT AUTHORIZING THE COMMISSION ON ELECTIONS TO USE AN AUTOMATED ELECTION SYSTEM IN THE MAY 11, 1998 NATIONAL OR LOCAL ELECTIONS AND IN SUBSEQUENT NATIONAL AND LOCAL ELECTORAL EXERCISES, TO ENCOURAGE TRANSPARENCY, CREDIBILITY, FAIRNESS AND ACCURACY OF ELECTIONS, AMENDING FOR THE PURPOSE BATAS PAMBANSA BLG. 881, AS AMEMDED, REPUBLIC ACT NO. 7166 AND OTHER RELATED ELECTIONS LAWS, PROVIDING FUNDS THEREFOR AND FOR OTHER PURPOSES.â€
3Ï‚rÎ½l1 Rollo (G.R. No. 199149), p. 166. Stipulation of Facts, Preliminary Conference Order dated September 16, 2010.cralawlibrary
4Ï‚rÎ½l1 Id. at 9-10.cralawlibrary
5Ï‚rÎ½l1 Id. at 10.cralawlibrary
6Ï‚rÎ½l1 Id. at 64-65. See Resolution No. 11-321.cralawlibrary
7Ï‚rÎ½l1 Rollo (G.R. No. 201350), pp. 116-119.cralawlibrary
8Ï‚rÎ½l1 Id. at 14-15. Petition.cralawlibrary
9Ï‚rÎ½l1 Id. at 128-130.cralawlibrary
10Ï‚rÎ½l1 Id. at 131-132.cralawlibrary
11Ï‚rÎ½l1 Id. at 133-138.cralawlibrary
12Ï‚rÎ½l1 Rollo (G.R. No. 199149), pp. 53-63.cralawlibrary
13Ï‚rÎ½l1 Id. at 273. As quoted in Resolution No. 11-281.cralawlibrary
14Ï‚rÎ½l1 Rollo (G.R. No. 201350), pp. 151-153.cralawlibrary
15Ï‚rÎ½l1 Id. at 158.cralawlibrary
16Ï‚rÎ½l1 Id. at 173-175.cralawlibrary
17Ï‚rÎ½l1 Rollo (G.R. No. 199149), p. 67. See Resolution No. 11-321.cralawlibrary
18Ï‚rÎ½l1 Id. at 64-69.cralawlibrary
19Ï‚rÎ½l1 Id. at 70-89.cralawlibrary
20Ï‚rÎ½l1 Id. at 91-104.cralawlibrary
21Ï‚rÎ½l1 Id. at 20-21.cralawlibrary
22Ï‚rÎ½l1 Rollo (G.R. No. 201350), pp. 124-127. Urgent Motion to Continue Revision to Include All Ballots in Protested Precincts.cralawlibrary
23Ï‚rÎ½l1 Id. at 161-164. Motion to Reiterate the Continuation of Revision (and to Schedule the Continuation of Revision on 24 May 2011 or at the Soonest Possible Date).cralawlibrary
24Ï‚rÎ½l1 Id. at 171-172. Order dated May 16, 2011.cralawlibrary
25Ï‚rÎ½l1 Id. at 178-184. Motion for Continuation of Revision Proceedings dated June 1, 2011; id. at 340-346. Motion for Revision (of Protested Ballots Not Covered by the Pilot Precincts) dated December 13, 2011.cralawlibrary
26Ï‚rÎ½l1 Id. at 70-73.cralawlibrary
27Ï‚rÎ½l1 Id. at 74-91. Motion for Reconsideration of Resolution No. 12-079; id. at 92-97. Supplemental Motion for Reconsideration of Resolution No. 12-079.cralawlibrary
28Ï‚rÎ½l1 Id. at 98-103.cralawlibrary
29Ï‚rÎ½l1 Id. at 28-30.cralawlibrary
30Ï‚rÎ½l1 DueÃ±as, Jr. v. HRET, G.R. No. 191550, May 4, 2010, 620 SCRA 78, 80.cralawlibrary
31Ï‚rÎ½l1 Citing Roque, Jr. v. COMELEC, supra note 1, at 139, which categorically pointed out that the PCOS is a paper-based technology.cralawlibrary
32Ï‚rÎ½l1 R.A. No. 9369, Sec. 2 (1).cralawlibrary
33Ï‚rÎ½l1 R.A. No. 9369, Sec. 2 (7).cralawlibrary
34Ï‚rÎ½l1 R.A. No. 9369, Sec. 2 (8).cralawlibrary
35Ï‚rÎ½l1 Automation Scenario, May 10, 2010 National and Local Elections, visited January 16, 2013.cralawlibrary
36Ï‚rÎ½l1 Roque, Jr. v. COMELEC, supra note 1, at 133.cralawlibrary
37Ï‚rÎ½l1 Id. at 130-131.cralawlibrary
38Ï‚rÎ½l1 Rollo (G.R. No. 199149), p. 143. Comment to the Petition.cralawlibrary
39Ï‚rÎ½l1 Wikipedia, The Free Encyclopedia, visited January 11, 2013.cralawlibrary
40Ï‚rÎ½l1 Rollo (G.R. No. 201350), pp. 173-175. Resolution No. 11-281.cralawlibrary
41Ï‚rÎ½l1 Rollo (G.R. No. 199149), pp. 128-130. Comment to the Petition.cralawlibrary
42Ï‚rÎ½l1 DueÃ±as, Jr. v. HRET, G.R. No. 185401, July 21, 2009, 593 SCRA 316, 339.cralawlibrary
43Ï‚rÎ½l1 G.R. Nos. 187958, 187961, and 187962, April 7, 2010, 617 SCRA 575.cralawlibrary
44Ï‚rÎ½l1 Rollo (G.R. No. 199149), p. 40. Petition.cralawlibrary
45Ï‚rÎ½l1 Rollo (G.R. No. 201350), p. 461. Comment to the Petition.cralawlibrary
46Ï‚rÎ½l1 Id. at 461-463.cralawlibrary
47Ï‚rÎ½l1 Supra note 42, at 336.cralawlibrary
48Ï‚rÎ½l1 Vilando v. House of Representatives Electoral Tribunal, G.R. Nos. 192147 & 192149, August 23, 2011, 656 SCRA 17, 32.cralawlibrary
49Ï‚rÎ½l1 Rollo (G.R. No. 201350), pp. 70-73.cralawlibrary
50Ï‚rÎ½l1 Supra note 42, at 338..comelec.gov.ph>