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ELECTION LAW LECTURE

Class, these are the Bar questions through the years. From 2010 to 2016. The Bar questions
pertaining to creating of new districts and plebiscites, Bar question on term limits, and then 2015-
2016, questions on parameters of party list representation.

So class we start with COMELEC, which we have studied. So by way of short review, who are
the qualified as appointees to COMELEC?

1. They must natural-born citizens of the Philippines

2. They must be at least 35 years old

3. A college degree holder

4. Must not have participated in the immediately preceding election

5. Majority of the members of the COMELEC must be members of the PH Bar. So majority. So
meaning, one, two or three can be an engineer, or an accountant. For example, Grace Padaca
who is an accountant. So what is important is that MAJORITY of the members must be coming
from the PH Bar.

What's the term of office? Seven (7) years. Composition is one (1) Chair and six (6)
Commissioners. Now the Constitution provides that of those first appointed, three members shall
hold office for 7 years, two members shall serve for 5 years, and the last members for 3 years.
What is the reason behind this scheme? So that the President will not have monopoly, and
number two, so that there be transfer of technology from the senior members to the junior
members.

Now the Constitution provides that there shall be no re-appointment of one who has served in
the COMELEC. And if one has died, how about his successor? Can he serve for 7 years? NO.
Only the unexpired portion.

Can the President in case of vacancy in the COMELEC, can he appoint an acting or temporary
Chair? He cannot. That would be an interference in the affairs of the COMELEC, which will destroy
the independence of the COMELEC as a Constitutional Commission. That's why in the case of
Brillantes v. Yorac if you could remember, because Yorac was appointed as Acting Chair and the
SC has ruled that the President cannot do that. Probably, what the remaining members can do,
is to select among themselves the most senior as Acting Chair.

By the way, I mentioned the term "independent" like COA and the CSC. Now the COMELEC Chair
submitted his resignation to the President, but why should he submit his resignation to the
President? Since the COMELEC is an independent commission, you are confirmed by the
Commission of Appoinments, so it is very unusual to submit his resignation to the President of
the PH.

We go to the powers of the COMELEC. What are the two (2) most important powers?
1. Enforce and administer laws and regulations relating to elections and plebiscite, recall
and referendum. That is one power class, wherein residual powers of the COMELEC
can be called. So they also have residual powers.

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2. Exercise original and exclusive jurisdiction over all contests and all election returns
qualification of regional, provincial and city officials, and appellate jurisdiction over
contests involving municipal elective officials from decisions of Courts with general
jurisdiction. And contests involving Barangay officials and SK from appeals of Courts with
limited jurisdiction.

Why is this important? If you recall the case of Grace Poe v. COMELEC, a petition for
disqualification was filed against Grace Poe, and the petition was filed with the Commission, and
the Commission have not realized, that the COMELEC has no jurisdiction, and their eyes were
opened only when the petition of disqualification against Grace Poe was filed. Remember that the
father, Fernando Poe, also was the subject for a petition of disqualification. Now in the case of
Grace Poe, the Court ruled that it is not covered, the Presidential Electoral Tribunal (PET) has
jurisdiction. The SC ruled in the case of Grace Poe, let her run, and if she wins, file a petition for
quo warranto. That is beyond the jurisdiction of the COMELEC, because as we have said,
regional, provincial and city officials. Okay?

What about candidates for mayor? Or councilor? With the RTC, for these municipal elective
officials. What about barangay chairman, and kagawad and SK? We file with the MTC. Only the
Municipal Courts. Huwag kayong magkakamali dahil kapag fi-nile niyo sa COMELEC yung
contest ng municipal official, it will be dismissed. Or the barangay officials with the RTC, it will
dismissed.

The no. 3 power is also important. Which is a Bar question many years ago. It is about
presidential pardon. In case of pardon, parole, amnesty, suspension of service of sentence, the
President cannot grant pardon in case of election offenses, unless with a favorable
recommendation from the COMELEC. Okay?

Now, another important power (no. 4) is that unless fixed by the COMELEC for special reasons,
the election period shall be 90 days before, the date of the election, and 30 days after. Why is it
important? Because in 2016, 2013, 2010 national elections the election period was 120 days not
90 days, as it appears in the Constitution. Why? Because it was fixed by the COMELEC for special
reasons. Okay?

There are cases which are decided by the COMELEC en banc or by divisions. So like SC
decisions. All protests, election protests, petition for registration of party list organizations,
[including pre-proclamation contests] petition for certiorari, they are all with the division, not en
banc. So all the cases decided by the division, the case is elevated to the en banc by motion for
reconsideration (MR). When you file MR in the division, it will be forwarded to the en banc for
decision and be treated as an appeal.

The only jurisdiction of the commission en banc is regarding election cases, meaning election
cases like violation of the Omnibus Election Code under Section 261, like when you violate the
provision on transfer of employees during the election period, the construction of public works
during the election period, these cases are decided with the COMELEC En Banc. But all others,
all the issues like registration of party list, certiorari, all these with the division.

Now, on Election Law this was a Bar question: the difference between Section 68 and Section
78. What is Section 68? Section 68 is a petition for disqualification. On grounds like:
1. Overspending
2. Giving money to election officers
3. Terrorism

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If you recall, one candidate was disqualified under Section 68, the Governor of Laguna, Gov.
Ejercito, for overspending. Now who replaced Gov. Ejercito? The vice governor, under the Local
Government Code (LGC). You will see class the difference between the two. The second highest
number of votes or the second placer rule from the rule of succession from the LGC.

What about Section 78? Section 78 class, is a petition to cancel certificate of registration or due
course. When you apply a petition under Section 78, it is with misrepresentation with the certificate
for registration. Like age, like residence, like citizenship. So if you misrepresent, then you file a
petition to deny due course or cancel the certificate of candidacy (COC).

When a COC is filed with the COMELEC with the election officers in the provinces or cities, can
the COMELEC question the COC and say “but you are disqualified, you are not yet a Filipino
citizen.” It cannot. Because under the Omnibus Election Code and supported by jurisprudence,
the role of COMELEC is simply to accept the COC. The role is ministerial. So that when one files
the COC with the COMELEC, they cannot question if there is a disqualification because the role
of COMELEC is simply to accept, okay, a COC on the basis of its ministerial function.

Now, rule on succession. This is now the “second placer rule” different from the rule of
succession in the LGC. A good example class would be the case of Aratea v. COMELEC. What
happened class in this case? The mayor who won was disqualified before the filing of the COC
because of judicial conviction. Meaning he was convicted, before the filing of the COC of
falsification of certain documents. So convicted before the filing of the COC. He filed though he
was convicted, and won. And SC has ruled you are disqualified because of the conviction the
penalty carries with it the penalty of perpetual disqualification from public office. Now because of
the disqualification, who will now succeed? It is the vice mayor or the second placer? The SC
has ruled it is the second placer. Because it is as if, there was no first placer, because he was
disqualified, there was no valid certificate of candidacy that was filed. Okay? So second placer
rule.

In Section 68, disqualification because of overspending, etc. etc. the successor will be the vice
governor, but in a situation where there was disqualification because of conviction, like in the case
of Aratea, it is the second placer. Okay?

Another example in the case of Maquiling v. COMELEC and Arnaldo v. COMELEC, what
happened class was Arnaldo was naturalized in the US. Now, here comes the election, he filed
his COC and was advised to renounce his foreign citizenship, but the advice was not complete,
because after renunciation, he continued to use his American passport. Now I was the
Commissioner during this case. I was a dissenting voice. The fact that he used his American
passport a number of times, it is as if he recanted his oath of renunciation. Now because I was a
minority, the case was elevated to the SC and the SC has ruled, in the case of Maquiling and
Arnaldo that the constant use of such passport even after one has renounced his foreign
citizenship, it is as if, he has recanted his oath of renunciation. So he was disqualified, though he
won, he has recanted, his oath of renunciation. So who will be the successor? Is it the vice
mayor? Or the second placer? The second placer. Because there is no valid COC. There is no
other contender for the position, so the second placer won in this case. That is the “second placer
rule”.

Now party list registration parameters. This we have discussed in the previous sessions.
What’s important to know is if they are a national organization or party, they can file for registration
not necessarily reflecting the interests of the marginalized and underrepresented. Because in the
case of Ang Bagong Bayani the national party organization should represent the interest of the

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party list and the underrepresented. Now no more. So when can form “Samahan ng mga Bagong
Abogado” or “Samahan ng mga Gwapong Bedista” without representing the marginalized and
underrepresented. Or regional parties or organizations. In the case of Ang Bagong Bayani you
cannot participate in the party list registration, if you do not represent the marginalized and
underrepresented. Today, under Atong Paglaum, you can participate provided that you register,
in the party list system of elections in the COMELEC and you will not field district
representatives. But if you will field district representatives, you have to work through a sectoral
representation. Okay?

What about the nominees? Before, in Ang Bagong Bayani, nominees should belong to the
marginalized and underrepresented. But today, a nominee need not belong to the
marginalized and underrepresented, what is important is that you advocate, you advocate
with a track record with same interests with these marginalized and underrepresented.

Creation of districts and provinces. The case involving this is the case of Aquino v. COMELEC.
A law was passed in creating a new district in Camarines Sur. One of the districts has less than
250,000 inhabitants. Now we have studied that for one congressman, there should be at least
250,000 population. So Senator Noynoy was questioning the issue of the creation of a new district
as violation. Now the SC has rejected the petition that they filed and ruled that the 250,000
inhabitants, for the creation of the districts has a reference to a city, but not to a district or a
district in the province. So, less than 250,000 in a district that is not a city, less than 250,000 is
okay.

In the case of Umali v. COMELEC, the Sangguniang Panlungsod of Cabanatuan City passed a
resolution that Cabanatuan City be converted from a component city to a highly-urbanized city.
The decision of the Sanggunian is that only the voters of Cabanautan will participate in the
plebiscite. But that was contested by Gov. Umali, who was a graduate of San Beda, saying that
the province would be affected. Economically, it would affect the province. And number two the
governor would lose the supervisory power over the highly-urbanized city. So it will affect the
province. Therefore [Umali’s stand was] all the voters of the province should vote, so the SC
sustained Mr. Umali. All the voters of the province should participate in the decision. Okay.

In recall, there is only one ground that is loss of confidence. That is the rule on recall. What if in
the recall, a mayor who has served for three terms, he was recalled when he was serving a third
term, and ran in another election for the recall, and he won. Did he violate the three-term limit
rule? He did not. Okay? So a mayor or one who was elected because of recall, though he has
surpassed the three-term limit will be an exception.

Note: An officer who has been elected and has served three consecutive terms will not be
disqualified to run for a recall election for the same position since there has been an interruption
in the continuity of terms of office after his third term (Socrates v. COMELEC).

Substitution. Now before class, during the manual elections, there is a space in the ballot, so
that in case that the candidate dies or suffers disability, or incapacitated, you can simply write the
name of the substitute. Sabihin natin Habihan, pinalitan ni Ilaya, o Roxas, pinalitan ni Apostol,
pwede yan. Under the manual system of elections. But today because we are automated, thus
with the printing of ballots, what is the rule? In case the candidate dies or is incapacitated, who
will be the substitute? The rule is that he should bear the same surname and should belong to
the same political party, to qualify as a substitute candidate. Why is this? Because the ballots
have been printed. We do not write the names, we simply shade the circle. So for example,

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Gonzales, Gonzales din. Manglapus, Manglapus din. Hindi pwedeng Mabunga. And he should
belong to the same political party.

Now the other rule is that, if the substitution was made after the deadline of the filing of the
COC, as in the case of Sto. Tomas, where mayor died, so the wife has to substitute, the wife vied
for governor. Nakalaban si Vilma Santos. So in replacing, a certain Federico, filed the COC after
the deadline, now Federico was complaining because his votes plus the votes of the candidate
who was elevated for the governorship was added to his number of votes. But the SC has ruled,
the votes for the woman who ran for governor as substitute of her husband, cannot be added to
this Federico because he filed his COC after the deadline of filing. So that his votes as considered
as stray votes. [Sorry di ko talaga maintindihan. Hindi ko alam saan galing si Federico ]

How do you differentiate quo warranto from protest? Two different things. A quo warranto,
any registered voter can file quo warranto on two grounds: disloyalty to the Republic and
ineligibility. What about protest? What are the grounds? Election irregularities, all of the election
irregularities but only those who ran for election, only those candidates can file protest. Okay?
Again in quo warranto, anyone, any voter can file a petition of quo warranto.

Term limits. Term limits, this is class a Bar question a few years ago. The decision class that
summarizes the rules on term limits is the case of Abundo v. COMELEC. And what is this Abundo
case all about. Abundo ran for mayor in 1991. Ran for election in 1994. In 1994, he lost but won
in the protest. So 1991, 1994, 1997. In 1997 he ran again, nanalo siya. He ran for the 4 th time,
he’s now being questioned, [based on the three-term limit rule]. Now the SC has ruled, because
he has not fully-served his term. Because though he won in the election protest, he did not fully
served his term. Because he did not serve, but in the protest he won, he did not violate the three-
term limit rule. Okay?

What about the case of Lonzanida v. COMELEC? What happened in the case of Lonzanida? In
1989, he won as mayor. May taga Zambales ba dito? Wala? In 1989 he won, in 1992, he ran for
re-election and he won. Third time, after three years he won but lost in the protest. Baliktad kesa
sa Abundo. Yun lost, but won. Ito si Lonzanida, won but lost. So he ran for the fourth time. Can
he run for the fourth term? Yes, because though he won, he lost in the protest, he did not fully
serve his term. So kulang pa din. He can run for the fourth time. He ran for the fourth term but he
has been disqualified for conviction. Had he not been disqualified, he can run.

Suspension. We have studied that the Ombudsman, the Sandiganbayan can suspend public
officers. Okay? What if they are suspended? The case is Aldovino v. COMELEC. What if they are
suspended, can they claim that they have not fully served the term? The SC ruled no. Because
when you are suspended, you could serve as mayor. The suspension was temporary. After the
service of the suspension, you still continue to serve as mayor. So the SC has ruled no, you
cannot invoke the argument that you are suspended and therefore you cannot run again after
serving three terms.

Another case class is about a vice mayor. The vice mayor succeeded the mayor who died while
in office. So he became a mayor. Now this vice mayor served for three terms as mayor [including
the succession because of death of previous mayor]. Can he run for the fourth term? Yes he can
run. Because he only served the unexpired portion of the previous mayor.

What if in the case of a municipality that became a city? Can the mayor now run for mayor of
the city? SC has ruled, cannot be. Because the voters are the same. You cannot run for the
position as mayor after the three term limit rule.

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Now prosecution of election offenses. In the Omnibus Election Code class, the power to
investigate and to prosecute is solely and exclusively vested in the COMELEC. But today in RA
No. 9369, it is the new law on automation, the power is shared concurrently with the prosecuting
arm of the Department of Justice (DOJ).

Qualified candidates. There was a resolution passed by the COMELEC, that all candidates
before they file their COC, they should also have funds. The purpose is to discourage nuisance
candidates. So that was passed by COMELEC. Election funds to discourage nuisance
candidates. But that was declared unconstitutional, because according to the SC it is an additional
qualification, to the qualification listed under the Constitution.

Now COMELEC and HRET. The case is Sampayan v. Daza. Daza was the subject of a petition
for disqualification with the COMELEC. While the case was pending, he was proclaimed
congressman. According to the SC, the jurisdiction is the HRET.

There is a new one. The new case of Reyes v. COMELEC. The congressman who fought in
Marinduque, the lone district of Marinduque. There was a petition for disqualification for against
Congresswoman Reyes. So she was proclaimed. She took her oath and assumed her duties.
Now in the case of Reyes, the oath taking is before the Speaker of the House. The SC has added
a new qualification. The oath taking should be before the plenary session of congress. So oath
taking before the Speaker is incomplete. So the COMELEC retains jurisdiction over the case,
because the acts were not complete: proclamation, oath taking before the Speaker of the House
and all members of Congress in a plenary session, plus assumption of duties.

RA No. 9225. There are questions regarding RA 9925. This is the citizenship retention and the
acquisition. If you are a naturalized American, you decided to run for office in the PH, you have
to renounce, sworn express renunciation of your citizenship. Okay? Example in the case of De
Guzman v. COMELEC. Naging Amerikano, nagtrabaho sa Amerika, bumalik tumakbong vice
mayor, nanalong vice mayor sa Nueva Ecija, nacontest, panalo pero but has been disqualified.
For lack of a good advice, filed his COC before renouncing his foreign citizenship.

Now this case of De Guzman is different from Manzano. Because in the Manzano case, the
parents are Filipinos. So he has dual citizenship, and all his all other acts and commissions. So
in Manzano the SC held that it is enough that he filed his COC which contains his Oath of
Allegiance, because he did not apply to be a naturalized citizen.

So master niyo na class, ang Bar questions, 2010-2016. Papasa na kayo class.

We go so some concepts which could be asked.

We go to suffrage. Never mind history, di naman tinatanong sa Bar yan e. In the previous
Constitutions, the Constitution provides, suffrage "shall". You violate it class, then you can be
prosecuted for an election offense which is found in the Omnibus Election Code, which is still now
amended until today. Now under the 1987 Constitution, you may or may not exercise your right
to vote. But there are many cases of tie votes. So one vote spells a difference. Also in the SK
elections. So many tie votes. And the cases reach the COMELEC.

One vote, and you can be a barangay Chairman. If there is one officer class who exercises so
many functions, it is the barangay chairman. He has executive, legislative and administrative
functions. It is he who appoints the lupon tagapamayapa. And the lupon tagapamayapa they call

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themselves "justices". If he wants to study advance studies, you can enroll in any SUC. Ang
daming benefits. My funeral, my death benefits pa din sila. Sila are the little mayors in the
barangays.

Now automated election system, meaning it's a system of appropriate technology, which has been
illustrated in the voting, canvassing and transmission of election results. That is the automated
election system. From 1907 to before 2010, election was manual. But from 2010 thereafter, the
election was automated.

Now precinct, polling station and voting centers. Are they different from each other or the
same? Now precinct class is the geographical unit, designated by the COMELEC. Example:
Barangay Dona Aurora, Barangay Don Manuel, Dona Josefa. If it has 200 votes, it will be precinct
1. Now if it is double [?] precinct, meaning the votes exceed 200, it will be precinct 1-A. So precinct
refers to a geographical unit designated by the COMELEC. So what about the polling stations?
It is where you vote. It is where the bulk of election would be, and where you would transact
business. So if it is in a building, the room are the polling stations but the building is the voting
center. Okay?

What about activation and deactviation? If you fail to vote in two regular elections. Now SK is
not a regular elections. If you failed to vote twice in two successive regular elections your
registration would be deactivated. It will be placed in the inactive files. Another instance is when
you become a foreign citizen. Your records will be deactivated. Or you’re convicted for an offense
where the penalty is less than a year, and then after 5 years, your record can be activated. So
that is deactivation.

Now what about reactivation? You want to reactivate your deactivated registration record? Go
to the local election officer. Fill up a form, sign an affidavit, your record will be reactivated. *Chika
about CJ Davide's deactivated registration, why Justices of the SC are not allowed to teach*

Cancellation. Once you die, your registration shall be cancelled forever. Under RA No. 8189
there is an obligation of the Office of the Civil Registrar to inform regularly the COMELEC about
those who die. That's why we see in the list of voters during the election, "ay kilala ko yan eh,
patay na yan 5 years ago. Itong mga taga COMELEC walang ginagawa. Pabaya!" but that is the
obligation of the Office of the Civil Registrar. They have the records. So they have to inform the
COMELEC regularly for the list of voters.

Campaign period and election period. What is the difference? What is the campaign period
class? Under the Omnibus Election Code, it is 90 days before the date of the election for national.
What about local candidates like mayors, governors, and even congressmen? How many days?
45 days before the date of the election. What about barangay candidates? How many days? 15
days before the date of the election. That would be the campaign period. And there is no more
period after the date of the election, unlike the election period that is 90 days before, and 30
days after, or to be extended to 120 days. Okay?

Jurisdiction of contests. MTC has jurisdiction involving contests in barangay officials.

Metropolitan, barangay and SK. RTC, municipal mayors and vice mayors, as well as councilors.
COMELEC, for regional, provincial or city officials. Okay? HRET, for congressmen. COMELEC is
divested of jurisdiction, once proclaimed, oath of office has been done personally in the presence
of the entire congressmen in a plenary session and assumed duties. SET, for senators. PET for
president and vice president.

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Rules of Procedure in the COMELEC, we have more or less discussed this. Now there is one
innovation in the Rules of Procedure, the 20 percent final precint rule. What does this mean?
In the contest or recap, the protester has to select 20 percent of the protested precints of the total
of 200 prostested precints. So 20 percent of the 200. That would be recounted. Now if in the
recount, the terms are similar, and the protester has not given votes as open to be examined, the
80 percent will be disregarded. The protest will be dismissed. So the test is the result of the 20
percent precint rule.

Supreme Court decisions on election law. The case of Poe-Llamanzares v. COMELEC, can a
foundling run for public office. Yes. But for the grounds, number one, based on their looks,
according to the SC decision. One can say that she is a Filipina. Number two, based on statistics,
because when Grace Poe was found in Iloilo, most were Filipinos, and number three, because
she has renounced her foreign citizenship and sold her properties in the US, and transferred to
the PH. And next would be the social justice principle and international law. The international law
and social justice favor the foundlings. So they could run for a public position.

Ipso facto resignation. What is this? Let's say you are a mayor. You want to run for the position
of governor. You filed a COC for the position of the governor. Does that mean ipso facto
resignation? No. Under the old doctrine, yes. But in the case of Farinas v. COMELEC, and
subsequent cases, if you filed your COC as congressman, you are not deemed resigned because
of the mandate that you have received from the people. That you have to serve. Now under the
old doctrine, exempted from the application of this doctrine is those who run for President. That
was an exception in the Omnibus Election Code under the old doctrine.

But today, the rule is, so long as you an elective official, running for any position, no ipso facto
resignation. What if you are an appointive official? You are say, Secretary Urban Xavier? You are
Asec Kristen. You are Usec Racca, or Regional Director Manuel. These are appointive officials.
Once you file your COC under Quinto v. COMELEC, there is ipso facto resignation. Why the
difference? Because the purpose of the law is to level the playing field. Because if you are an
appointive official, there can be so many resources. So appointive officials, ipso facto resignation.

Premature campaigning. There is no more premature campaigning today. Before the start of
the campaign period, the 90 days, 45 days, 15 days if you campaign, meaning advertise yourself,
using tarps, streamers or accepting guesting in talk shows or congratulating the graduates, or
greeting happy valentine's, and your name appears in the tarpaulin, that was an election offense
of premature campaigning under the old rule. Under the old rule, you can campaign only during
the start of the campaign period. But under the case of Pineda v. COMELEC, it says, you become
only a candidate not when you file your COC, just imagine, you filed your COC but you are not a
candidate, e nag-file ka na. You are a candidate officially when the campaign period has started.
So that one before the campaign, you can resort to campaigning. You can advertise yourself,
there is no violation. Now there could be a relation, following this case of Pineda, as the start of
the campaign period. But if at the start of the campaign period nag-kakampanya ka na, paano
papasok yung violation? Except for the size of the tarp, size of the streamers etc. etc. So there is
a vacuum in the law.

Now the case of Marcos v. Manglapus, resident and domicile are the same thing, in election law
and political law. So what is important in this case is even when you have stayed for a long time,
in Metro Manila, so long as you have the intent to return to your place of abode, even if you have
been absent for many, many years, you are still qualified to run for governor, congressmen etc.
Of course there is a need of establishing your residence. Because residence is physical, dapat
may bahay ka din na binabalik-balikan sa probisya.

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Nuisance candidates. Who are these nuisance candidates? They are those who:
1. Wage a national campaign
2. Confusingly similar to other candidates

In the case of Dela Cruz v. Dela Cruz, we have a new doctrine. What is the doctrine? Before, the
votes of nuisance candidates are declared as stray votes, not counted, but today in the case of
Dela Cruz, they ran as vice mayor, the two Dela Cruzes, the nuisance candidate won, but was
disqualifid. The rule now is, his votes should be added in the legitimate candidate. To the
legitimate Dela Cuz. Instead of nullifying those votes, they should be added to the legitimate Dela
Cruz.

Protest of presidential candidates. Examples would be your favorite senator Miriam Defensor-
Santiago. She ran for President, she lost. Ramos won. She filed a protest with the Presidential
Electoral Tribunal (PET), now while the case was pending she ran for the senate and vote. Now
what happens to the electoral protest? It is deemed abandoned. Another example would be
Senator Loren Legarda. Ran for the vice president against Kabayan De Castro. She lost. While
the case was pending in the PET, she ran for senate and won. What happened to her protest?
Deemed abandoned.

Pre-proclamation controversy. Under the Code there are so many grounds so file a pre-
proclamation controversy in the COMELEC. Like the election returns are defective, fruit of
coercion, of fraud, etc. etc. But today under the new law, only two grounds: illegal composition of
board of canvassers and illegal proceeding in the board of canvassers. Based on the previous
Bar exams, there are no questions yet on pre-proclamation controversy. Madalang itanong sa
Bar.

Okay, we're done. Any questions?

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