REPUBLIC OF THE PHILIPPINESCOMMISSION ON ELECTIONS

SALSA EZA GUZMAN,

Petitioner,

vs.

ATTY. JASUN ABABA,

Respondent.

JUNE 5, 2014xxxxxxxxxxxxxxxxxxxxxxxxx

PETITION

Petitioner through counsel respectfully alleges:

1. That Atty. Jasun Ababa is a qualified voter and was one of the registered candidates for mayoralty voted for in the general election held on 10th day of May, 2014 in Quezon City, Philippines, within the jurisdiction of the court;

2. That according to the certificate of canvass of the city board of canvassers for the city of Quezon, the total votes for the office of the City Mayor for the said Citywas 30,000 the respondent appearing to have received 17,250 votes, the petitioner12,750 votes;

3. That on 11th day of June, 2014, the said city board of canvassers proclaimed the respondent Atty. Jasun Ababa elected to the office of the City Mayor of Quezon City;

4. That the petitioner contests the election of the said respondent on the following grounds:

On the said canvassing day, certain irregularities happened in lieu of the intimidations and threats in the part of the party of Atty. Ababa. Outside the precinct 10, where the said canvassing happened, the members of the group of Atty. Ababa kept on shouting and disturbing the silence and peacefulness of the environment of the canvass. Thus, it made interruptions to the canvassing which made the canvassers re-counted again and again for 3 times the said ballots because they are being disturbed by the said group.

One of the officer went outside the said Precinct and shouted with an authoritative voice in ordering them to be silent and to stop disturbing the serenity of the canvass of election returns. But, this act made a greater cause of disturbance, in which the same group fought back by throwing stones and bad words against the said officer. Because of which, the officer merely went back inside the precinct and told the canvassers of the reactions of the said group.

And so, the canvassers continued their call of duty, notwithstanding the nuisance simultaneously disturbing them. Thus, this caused the miscalculation and miscounting of the said ballots of votes.

5. That the petitioner is willing to give a bond, as this Honorable Court may determine to cover all reasonable expenses and costs and damages, incidental to these proceedings;

WHEREFORE, it is respectfully prayed:

1. That upon service of summons in accordance with law, a day be set for the hearing of the protest;

2. That an order be issued to the city treasurers of the Quezon City to bring and present before the Honorable Court on or before the day of the hearing of this protest the ballot boxes, copies of the registry list, the election statements, the voters affidavits, and other documents used in the said election in said municipalities, in order that this Honorable Court may re-examine and revise the same;

3. That after due proceedings, the election for the mayoralty of Quezon City of the respondent be annulled and that the petitioner be declared dulyelected instead;

4. That the expenses and costs incurred in these proceedings be assessed against the respondent.

IN WITNESS WHEREOF, here in Quezon City, Philippines, this 5th day of June 2014.

PETITIONER:

SALSA EZA GUZMAN

COUNSEL:

ATTY. CAVIN RIGORAppointment No. 3425Roll of Attorney No. 123789PTR No.12, 56 Jan. 1, 2014 Quezon CityIBP No. 1234,566 Jan. 1, 2014Office Address: San Bartolome, Novaliches Quezon City