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	GR No. 182221 2010-02-03	THEMISTOCLES A. SAÑO v. COMELEC DEL CASTILLO, J.
It is settled that a pre-proclamation controversy is summary in character;[42] indeed, it is the policy of the law that pre-proclamation controversies be promptly decided, so as not to delay canvass and proclamation.[43] The Board of Canvassers (BOC) will not look into allegations of irregularity that are not apparent on the face of ERs that appear otherwise authentic and duly accomplished.[44]
	GR NO. 164922 2005-10-11	RAYMOND P. ESPIDOL v. COMELEC CALLEJO, SR., J.
Admittedly, the Court had the occasion to state that lack of inner paper seals in the election returns does not justify their exclusion from canvassing and that such is not proper subject of a pre-proclamation controversy.[42] However, in the present case, aside from the lack of inner paper seals, private respondent Tabag raised other grounds for the exclusion of certain election returns, including lack of signature of the Chairman of the BEI and absence of thumbmarks of the members of the BEI.