On December 3, 2025, the Supreme Court issued a landmark ruling redefining the treatment of votes cast for nuisance candidates in Philippine elections. In its decision, the Court held that votes cast for nuisance candidates — whose certificates of candidacy have been canceled or rejected — must be considered stray votes and cannot be credited to any other candidate.
Background of the Case
The ruling, penned by Associate Justice Maria Filomena D. Singh, arose from Amutan v. COMELEC (G.R. No. 266331), a case involving the 2022 elections for Cavite’s 5th District Board Member.
Marcos “Macoy” Cabrera Amutan was initially proclaimed a winner. However, the Commission on Elections (COMELEC) later declared another candidate, Alvic Madlangsakay Poblete, a nuisance candidate and transferred Poblete’s votes to Francisco Paolo Poblete Crisostomo, altering the final results. As a consequence, Amutan’s proclamation was cancelled and Crisostomo was declared the winner.
Supreme Court’s Ruling
The Supreme Court reversed this outcome and invalidated the transfer of votes. It ruled that votes cast for nuisance candidates are stray votes that cannot be credited to anyone else, even in cases of name confusion.
The Court’s Reasoning
The Court explained that earlier cases—such as Dela Cruz v. COMELEC—were decided during the era of manual elections, when voters wrote names by hand on ballots. Because handwriting could be unclear or incomplete, determining voter intent sometimes required interpretation. In those cases, votes for nuisance candidates were occasionally credited to legitimate candidates to reflect what the voter likely intended.
But with today’s automated election system (AES), voter intent is unmistakably captured. Every mark corresponds directly to a specific candidate, since voters simply shade the oval beside the full name or nickname of their chosen candidate. This setup eliminates ambiguity and removes the possibility of “vague” or misread votes. In short, under AES, there are no more ‘vague votes’ to speak of.
Given this clarity, the Court concluded that there is no legal, factual, or practical basis to transfer votes from nuisance candidates to anyone else. This approach aligns with the Omnibus Election Code, which treats nuisance candidates as if they never filed a certificate of candidacy at all. Consequently, any votes cast for them cannot legally be credited to another candidate and must be treated strictly as stray votes, in order to protect voter intent and uphold the integrity of election results.