(Final File) 2022 2026 COLLATED CASE DIGESTS and DOCTRINES

COLLATED COMELEC CASE DIGESTS and DOCTRINES 2022-2026

2022-2026 Case Digests and Doctrines Page 1 of 128

2022-2026 Case Digests and Doctrines Page 2 of 128 CONTENTS 2022 Case Digests .................................................................................................................... 8 UDK-16915 ............................................................................................................................... 9 JOSEPH ROBLES PENAS Versus COMISSION ON ELECTIONS, Represented by the CAMPAIGN FINANCE UNIT .......................................................................................... 9 G.R. No. 221201 ..................................................................................................................... 12 Atty. Victor Aguinaldo versus New Bilibid Prison (Bureau of Corrections), Department of Justice, Commission on Elections, Bureau of Jail Management and Penology, Different Municipal, City and Provincial Jails in the Philippines, and Enlisted Voters of the New Bilibid Prison and/or Detainees .................................... 12 G.R. No. 243968 ..................................................................................................................... 14 Angelo Castro De Alban versus Commission on Elections (Comelec), Comelec Law Department and Comelec Education and Information Department......................... 14 G.R. No. 260374 / G.R. No. 260426..................................................................................... 17 Fr. Christian B. Buenafe, Fides M. Lim, Ma. Edeliza P. Hernandez, Celia Lagman Sevilla, Roland C. Vibal, and Josephine Lascano versus Commission on Elections, Ferdinand Romualdez Marcos, Jr., The Senate of the Philippines, represented by the Senate President, The House of Representatives, represented by the Speaker of the House of Representatives/Bonifacio Parabuac Ilagan, Saturnino Cunanan Ocampo, Maria Carolina Pagaduan Araullo, Trinidad Gerilla Repuno, Joanna Kintanar Cariño, Elisa Tita Perez Lubi, Liza Largoza Maza, Danilo Mallari Dela Fueta, Carmencita Mendoza Florentino, Doroteo Cubacub Abaya, Jr., Erlinda Nable Senturias, Sr. Arabella Cammagay Balingao, Sr. Cherry M. Ibardolaza, CSSJB, Sr. Susan Santos Esmile, SFIC, Homar Rubert Roca Dastajo, Polynne Espineda Dira, James Carwyn Candila, and Jonas Angelo Lopena Abadilla vs. Ferdinand Romualdez Marcos, Jr., The Senate of the Philippines, represented by the Senate President, The House of Representatives, represented by the Speaker of the House of Representatives ............................................................................................................. 17 G.R. No. 258435 ..................................................................................................................... 22 NORMAN CORDERO MARQUEZ, PETITIONER, VS. COMMISSION ON ELECTIONS, RESPONDENT.......................................................................................... 22 G.R. No. 247645 ..................................................................................................................... 25 Liberal Party, represented by its President, Francis N. Pangilinan, and/or Its Secretary General, Jose Christopher Y. Belmonte vs. Commission on Elections and Nacionalista Party, represented by its President, Manuel B. Villar, and/or its Secretary General, Alan Peter Cayetano ........................................................................ 25

2022-2026 Case Digests and Doctrines Page 3 of 128 G.R. No. 258456 ..................................................................................................................... 27 GIORGIDI B. AGGABAO and AMELITA S. NAVARRO Versus COMMISSION ON ELECTIONS (COMELEC) and LAW DEPARTMENT ................................................ 27 G.R. No. 258448 ..................................................................................................................... 30 Wilson Caritero Amad vs. Commission on Elections.................................................. 30 G.R. No. 257453 ..................................................................................................................... 33 MARIZ LINDSEY TAN GANA-CARAIT Y VILLEGAS, VS. COMMISSION ON ELECTIONS, ROMMEL MITRA LIM, AND DOMINIC P. NUÑEZ ........................ 33 2023 Case Digests .................................................................................................................. 35 G.R. No. 255509 ..................................................................................................................... 36 Edwin D. Rodriguez and Michael T. Defensor vs. Commission on Elections, Maria Josefina G. Belmonte, Gian Carlo G. Sotto, Wilfredo B. Revillame, and Elizabeth A. Delarmente ......................................................................................................................... 36 G.R. No. 263061 ..................................................................................................................... 38 GLENDA BURAY ECLEO, PETITIONER, VS. COMMISSION ON ELECTIONS, RESPONDENT. ................................................................................................................. 38 G.R. No. 257610 ..................................................................................................................... 41 Glen Quintos Albano vs. Commission on Elections .................................................... 41 G.R. No. 261344 ..................................................................................................................... 43 Frank Ong Sibuma vs. Commission on Elections, Alma L. Panelo, and Stefanie Ann Eriguel Calongcagon ........................................................................................................ 43 G.R. No. 262622 ..................................................................................................................... 45 PRYDE HENRY A. TEVES, PETITIONER, VS. COMMISSION ON ELECTIONS, ROEL R. DEGAMO, AND GREGO "RUEL" DEGAMO RESPONDENTS. .............. 45 G.R. No. 262682 ................................................................................................................. 45 GREGO "RUEL" G. DEGAMO, PETITIONER, VS. COMMISSION ON ELECTIONS AND ROEL R. DEGAMO, RESPONDENTS. ............................................................... 45 February 14, 2023 .............................................................................................................. 45 G.R. No. 259354 ..................................................................................................................... 49 National Press Club of the Philippines, Automated Election System Watch, and Guardians Brotherhood, Inc. versus. Commission on Elections................................ 49 G.R. No. 257427 ..................................................................................................................... 52 Florida P. Robes vs. Commission on Elections ............................................................. 52

2022-2026 Case Digests and Doctrines Page 4 of 128 G.R. No. 242255 ..................................................................................................................... 55 PROVINCE OF SULU, DULY REPRESENTED BY ITS GOVERNOR, ABDUSAKUR A. TAN II versus PHILIPPINE ASSOCIATION OF ISLAMIC ACCOUNTANTS [PAIA], INC., REPRESENTED BY ITS PRESIDENT, AMANODING D. ESMAIL, CPA, ET AL.; GOVERNOR ESMAEL G. MANGUDADATU, ET AL.; AND ALGAMAR A. LATIPH, ET AL.; PETITIONERS-IN-INTERVENTION; VS. HON. SALVADOR C. MEDIALDEA, IN HIS CAPACITY AS EXECUTIVE SECRETARY; HONORABLE EDUARDO M. AÑO, IN HIS CAPACITY AS OFFICER-IN- CHARGE OF THE DEPARTMENT OF INTERIOR AND LOCAL GOVERNMENT; THE HONORABLE SENATE OF THE PHILIPPINES; THE HONORABLE HOUSE OF REPRESENTATIVES; THE HONORABLE COMMISSION ON ELECTIONS; HONORABLE JESUS G. DUREZA, IN HIS CAPACITY AS SECRETARY OF THE OFFICE OF THE PRESIDENTIAL ADVISER ON THE PEACE PROCESS; BANGSAMORO TRANSITION COMMISSION; AND MORO ISLAMIC LIBERATION FRONT ...................................................................................................... 55 G.R. No. 260116 ..................................................................................................................... 59 Agnes C. Villanueva v. Commission on Elections ....................................................... 59 G.R No. 264029 ...................................................................................................................... 61 JOENAR VARGAS AGRAVANTE, PETITIONER, VS. COMMISSION ON ELECTIONS, MUNICIPAL TRIAL COURT OF GOA, CAMARINES SUR, AND JOSEPH AMATA BLANCE, RESPONDENTS. ............................................................ 61 G.R. NO. 260650 .................................................................................................................... 64 ROBERTO “PINPIN” T. UY, JR. Versus COMMISSION ON ELECTIONS .............. 64 G.R. No. 258805 ..................................................................................................................... 69 St. Anthony College of Roxas City, Inc vs. Commission on Elections ...................... 69 2024 Case Digests .................................................................................................................. 71 G.R. No. 261107 ..................................................................................................................... 72 ANA LIZA ARRIOLA PERALTA, PETITIONER, VS. COMMISSION ON ELECTIONS, REPRESENTED BY THE CAMPAIGN FINANCE UNIT, RESPONDENT. ................................................................................................................. 72 G.R. No. 270564 ..................................................................................................................... 75 SMARTMATIC TIM CORPORATION AND SMARTMATIC PHILIPPINES, INC., PETITIONERS, VS. COMMISSION ON ELECTIONS EN BANC, ELISEO MIJARES RIO, JR., AUGUSTO CADELIÑA LAGMAN, FRANKLIN FAYLOGA YSAAC, AND LEONARDO OLIVERA ODOÑO, RESPONDENTS. ....................................... 75 G.R. No. 262975 ..................................................................................................................... 77

2022-2026 Case Digests and Doctrines Page 5 of 128 Magkakasama Sa Sakahan vs. Commission on Elections and Soliman Villamin,Jr. .............................................................................................................................................. 77 G.R. No. 258449 ..................................................................................................................... 79 JUAN JUAN OLILA OLLESCA, PETITIONER, VS. COMMISSION ON ELECTIONS, RESPONDENT.......................................................................................... 79 G.R. No. 264661 ..................................................................................................................... 81 Clarylyn A. Legaspi, et al. vs. Commission on Elections ............................................ 81 G.R. No. 273136 ..................................................................................................................... 84 Eliseo Mijares Rio, Jr., Augusto Cadelina Lagman, and Franklin Fayloga Ysaac versus Commission on Elections En Banc. ..................................................................... 84 G.R. No. 264071 ..................................................................................................................... 88 Ben D. Ladilad vs. Commission on Elections and Mary Grace Bandoy ................... 88 G .R. No. 265847 .................................................................................................................... 91 MA. ZARAH ROSE DE GUZMAN-LARA vs. COMMISSION ON ELECTIONS and MANUEL N. MAMBA, .................................................................................................... 91 G.R. No. 268546 ..................................................................................................................... 94 AN WARAY Party-List, represented by Florencio Gabriel “Bem” Noel and Victoria Isabel Noel versus Commission on Elections, Danilo T. Pomias, Jr., and Jude A. Acidre.................................................................................................................................. 94 G.R.No. 261123 ...................................................................................................................... 97 Duty to Energize The Republic Through the Enlightenment of the Youth [Duterte Youth] Party-List vs. Commission on Elections ........................................................... 97 G.R. No. 242255 ................................................................................................................... 100 PROVINCE OF SULU, DULY REPRESENTED BY ITS GOVERNOR, ABDUSAKUR A. TAN II, versus PHILIPPINE ASSOCIATION OF ISLAMIC ACCOUNTANTS [PAIA], INC., REPRESENTED BY ITS PRESIDENT, AMANODING D. ESMAIL, CPA, ET AL.; GOVERNOR ESMAEL G. MANGUDADATU, ET AL.; AND ALGAMAR A. LATIPH, ET AL.; PETITIONERS-IN-INTERVENTION; VS. HON. SALVADOR C. MEDIALDEA, IN HIS CAPACITY AS EXECUTIVE SECRETARY; HONORABLE EDUARDO M. AÑO, IN HIS CAPACITY AS OFFICER-IN- CHARGE OF THE DEPARTMENT OF INTERIOR AND LOCAL GOVERNMENT; THE HONORABLE SENATE OF THE PHILIPPINES; THE HONORABLE HOUSE OF REPRESENTATIVES; THE HONORABLE COMMISSION ON ELECTIONS; HONORABLE JESUS G. DUREZA, IN HIS CAPACITY AS SECRETARY OF THE OFFICE OF THE PRESIDENTIAL ADVISER ON THE PEACE PROCESS;

2022-2026 Case Digests and Doctrines Page 6 of 128 BANGSAMORO TRANSITION COMMISSION; AND MORO ISLAMIC LIBERATION FRONT, RESPONDENTS..................................................................... 100 G.R.No. 263828 .................................................................................................................... 104 Avelino C. Amangyen vs. the Commission on Elections and Franklin W. Talawec ............................................................................................................................................ 104 G.R. No. 264125 ................................................................................................................... 107 Noel E. Rosal vs. Commission On Elections And Joseph San Juan Armogila/Oscar Robert H. Cristobal vs. Commission On Elections, Alfredo A. Garbin, Jr., Joseph San Juan Armogila, And Carmen Geraldine Rosal/Carmen Geraldine Rosal vs.Commission On Elections, Joseph San Juan Armogila, Alfredo A. Garbin, Jr., And Oscar Robert H. Cristobal/Jose Alfonso V. Barizo vs. Commission On Elections And Joseph San Juan Armogila ............................................................................................. 107 G.R No. 268891 .................................................................................................................... 111 GERARDO “JERRY” A. NOVERAS, PETITIONER Versus COMMISSION ON ELECTIONS AND NARCISO DELA CRUZ AMANSEC, RESPONDENTS ......... 111 2025 Case Digests ................................................................................................................ 114 G.R. Number: 276456 .......................................................................................................... 115 PARTIDO FEDERAL NG PILIPINAS AND ITS NATIONAL PRESIDENT LEANDRO B. VERCELES, JR., AND ON HIS OWN BEHALF AS A PARTY MEMBERS, PETITIONERS, Versus COMMISSION ON ELECTIONS, REYNALDO S. TAMAYO, JR., THOMPSON C. LANTION AND GEORGE S. BRIONES, RESPONDENTS. ............................................................................................................. 115 G.R. Nos. 260219 & 260231 ................................................................................................ 118 Datu Pax Ali versus Commission on Elections............................................................ 118 G.R. No. 277280 ................................................................................................................... 121 FRANCIS LEO ANTONIO MARCOS versus COMMISSION ON ELECTIONS ... 121 2026 Case Digests ................................................................................................................ 124 G.R.No. 279413 .................................................................................................................... 125 Errol B. Comafay, Jr., vs. Commission on Elections and Paquintos B. Sallaya ...... 125 G.R. No. 279008 ................................................................................................................... 128 258MERSON C. CALUBAG, PETITIONER, VS. COMMISSION ON ELECTIONS AND KIMBERLY P. JOSEPH, RESPONDENTS......................................................... 128

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2022-2026 Case Digests and Doctrines Page 9 of 128 UDK-16915 JOSEPH ROBLES PENAS Versus COMISSION ON ELECTIONS, Represented by the CAMPAIGN FINANCE UNIT February 15, 2022 DOCTRINE: The constitutional right to the speedy disposition of cases applies to preliminary investigations conducted by the COMELEC. When the Commission fails to resolve a case within a reasonable period and cannot sufficiently justify the delay, it commits grave abuse of discretion and the complaint may be dismissed for violation of the respondent's constitutional rights. The Court reiterated that: "All persons shall have the right to a speedy disposition of their cases before all judicial, quasi- judicial, or administrative bodies." Further, a respondent in a preliminary investigation is not duty-bound to follow up the case; it is the responsibility of the investigating agency to resolve it promptly. FACTS OF THE CASE In the 2010 National and Local Elections, Joseph Roble Peñas ran for Mayor of Digos City under the Nationalist People's Coalition (NPC). He later filed his Statement of Contributions and Expenditures (SOCE), declaring campaign expenditures amounting to ₱600,000.00. Subsequently, the COMELEC Campaign Finance Unit informed him that based on the number of registered voters in Digos City, he was allegedly allowed to spend only ₱281,403.00. He was therefore required to explain why no charges for election overspending should be filed against him. Peñas submitted an Affidavit of Correction/Explanation and later a Counter- Affidavit, asserting that certain amounts included in his SOCE represented expenses for the printing of sample ballots and attorney's fees incurred for the benefit of NPC candidates, which he claimed should not have been included in the computation of his campaign expenditures.

2022-2026 Case Digests and Doctrines Page 10 of 128 Despite his explanation, the COMELEC En Banc, through Resolution No. 18-0665 dated November 5, 2018, found probable cause and ordered the filing of an Information against him for election overspending. His motion for reconsideration was subsequently denied through Resolution No. 20-00121-33 dated December 9, 2020. Aggrieved, Peñas filed a Petition for Certiorari before the Supreme Court, arguing, among others, that the COMELEC violated his constitutional right to the speedy disposition of cases because it took approximately six years to complete the preliminary investigation. ISSUE Whether the COMELEC En Banc committed grave abuse of discretion amounting to lack or excess of jurisdiction in finding probable cause against Joseph Roble Peñas and ordering the filing of an Information for election overspending despite the inordinate delay in the conduct of the preliminary investigation. RULING Yes. The COMELEC En Banc committed grave abuse of discretion amounting to lack or excess of jurisdiction. RATIO DECIDENDI The Court held that the COMELEC violated Peñas' constitutional right to the speedy disposition of cases by taking an unreasonable length of time to resolve the complaint against him. The complaint was filed on November 6, 2014, while Peñas submitted his Counter- Affidavit on February 9, 2015. However, the COMELEC issued its Resolution finding probable cause only on November 5, 2018, or about four years after the filing of the complaint. It then took another two years to resolve his motion for reconsideration. In total, approximately six years elapsed before the preliminary investigation was finally concluded. The Court noted that under Section 8, Rule 34 of the COMELEC Rules of Procedure, a preliminary investigation must be terminated within twenty (20) days after receipt of the counter-affidavits and resolved within five (5) days thereafter. The COMELEC clearly failed to comply with its own prescribed periods.

2022-2026 Case Digests and Doctrines Page 11 of 128 Applying the guidelines in Cagang v. Sandiganbayan, the Court ruled that once the delay exceeded the prescribed period, the burden shifted to the COMELEC to justify the delay. The Commission failed to discharge this burden. The COMELEC merely argued that it had to administer the 2016 and 2019 national elections during the pendency of the case. The Court found this explanation insufficient, emphasizing that the case involved a simple issue of alleged overspending that required neither complicated legal questions nor voluminous evidence. The Court further held that the delay prejudiced Peñas. The prolonged investigation subjected him to uncertainty, anxiety, reputational damage, and impairment of his ability to defend himself because witnesses and documentary evidence might no longer be readily available. The Court likewise rejected the argument that Peñas had waived his right to a speedy disposition of his case. Citing Javier v. Sandiganbayan, it held that respondents in preliminary investigations are not required to follow up their cases, and COMELEC Rules themselves prohibit motions to dismiss. Thus, his failure to file motions demanding action could not be construed as acquiescence to the delay. Because the COMELEC failed to justify the delay and violated petitioner's constitutional right, the Court ruled that the Commission acted with grave abuse of discretion amounting to lack or excess of jurisdiction in ordering the filing of the criminal case against him.

2022-2026 Case Digests and Doctrines Page 12 of 128 G.R. No. 221201 Atty. Victor Aguinaldo versus New Bilibid Prison (Bureau of Corrections), Department of Justice, Commission on Elections, Bureau of Jail Management and Penology, Different Municipal, City and Provincial Jails in the Philippines, and Enlisted Voters of the New Bilibid Prison and/or Detainees March 29, 2022 DOCTRINE The Court’s power of judicial review may be exercised in constitutional cases only if all the following requisites are complied with: (i) the existence of an actual and appropriate case or controversy; (ii) a personal and substantial interest of the party raising the constitutional question; (iii) the exercise of judicial review is pleaded at the earliest opportunity; and (iv) the constitutional question is the lis mota of the case. FACTS OF THE CASE On March 6, 2012, the Commission on Elections (COMELEC) promulgated Resolution No. 9371, entitled the Rules and Regulations on Person Deprived of Liberty (PDL) Registration and Voting in Connection with the May 13, 2013 National and Local Elections and Subsequent Elections Thereafter. The Resolution defined persons deprived of liberty (PDL) who are qualified to register and vote, constituted a Committee on PDL Voting, laid down the guidelines for registration and voting, designated special polling places inside jails, and constituted a Special Board of Election Inspectors and their support staff. Atty. Victor Aguinaldo filed a petition assailing the validity of Resolution No. 9371, claiming that it: • failed to provide for its own implementing rules and regulations • did not undergo prior public consultations • violated the equal protection clause by favoring PDL voters over other classes of voters • failed to address operational and logistical blind spots. He prayed that Resolution No. 9371 be declared unconstitutional and that its implementation be restrained.

2022-2026 Case Digests and Doctrines Page 13 of 128 ISSUE Whether COMELEC Resolution No. 9371 is unconstitutional. RULING No. The Supreme Court dismissed the petition for failure to establish the requisites of judicial review and lifted the Temporary Restraining Order issued on April 19, 2016. Consequently, COMELEC may fully implement Resolution No. 9371. RATIO DECIDENDI The Court held that the power of judicial review may be exercised only if all the following requisites are complied with: 1. The existence of an actual and appropriate case or controversy; 2. A personal and substantial interest of the party raising the constitutional question; 3. The exercise of judicial review is pleaded at the earliest opportunity 4. The constitutional question is the lis mota of the case. The Court found that petitioner did not even bother to establish the foregoing requisites. It ruled that Atty. Aguinaldo failed to show legal standing because he did not suffer any direct injury arising from Resolution No. 9371. He also failed to establish taxpayer standing, voter standing, or third-party standing. The Court stressed that courts do not decide constitutional questions in the absence of an actual case or controversy, nor do they render advisory opinions based on speculative or hypothetical injuries. Since the requisites for judicial review were absent, the Court found no necessity to pass upon the constitutionality of the assailed COMELEC Resolution.

2022-2026 Case Digests and Doctrines Page 14 of 128 G.R. No. 243968 Angelo Castro De Alban versus Commission on Elections (Comelec), Comelec Law Department and Comelec Education and Information Department DOCTRINE A case becomes “moot” when it ceases to present a justiciable controversy by virtue of supervening events such that a declaration thereon would be of no practical use or value. For the Court to decide if a certain case is moot and academic, there should be four exceptions. First, if there is a grave violation of the Constitution; second, if the exceptional character of the situation and paramount public interest are involved; third, when the constitutional issue raised requires the formulation of controlling principles to guide the bench, the bar, and the public; and fourth, when the case is capable of repetition yet evading review. In this case, the doctrine was applied because of the fourth exception. The Court claimed that such circumstances could occur and follow the same course of events again, given that elections are held at regular intervals. Thus, compelling reasons exist for the Court to finally settle the questions raised in this petition through the application of this doctrine. FACTS OF THE CASE Angelo Castro De Alban filed his CoC for senator in the May 13, 2019, elections as an independent candidate, wherein he indicated that he is a lawyer and a teacher. Angelo Castro De Alban was one of the aspiring senatorial candidates who had been declared an alleged nuisance candidate by the COMELEC Law Department through its authority to motu proprio declare candidates they perceive as befitting under Section 69 of the Omnibus Election Code (OEC). De Alban’s financial capacity and his desire to run independently were put into question as to whether he was really capable of waging a nationwide campaign and whether he really had a bona fide intention of running for public office. De Alban, the petitioner, insisted that he was capable of waging a nationwide campaign through the utilization of a paid website and commissioned social media platforms like Facebook to give him visibility and promotion to the masses, and included his frequent domestic and international travels to prove his financial capacity. Additionally, to counter the COMELEC Law Department’s argument about his position as an independent candidate, he stated that he had secured statements of support from various groups.

2022-2026 Case Digests and Doctrines Page 15 of 128 On December 6, 2018, the COMELEC First Division declared De Alban a nuisance candidate. The COMELEC First Division cited that De Alban, despite his attempt to prove his financial capacity, still failed to establish that he was financially capable of waging a nationwide campaign, especially since he was running as an independent candidate. De Alban, opposing the COMELEC First Division’s decision, filed this Petition for Certiorari, ascribing grave abuse of discretion to the COMELEC in declaring him a nuisance candidate. De Alban claimed that Section 69 of the OEC, which gives the COMELEC the power to motu proprio refuse to give due course to or cancel a CoC, does not apply to aspiring senators, with the justification that the Omnibus Election Code became effective in 1985, before the creation of the Senate under the 1987 Constitution, implying that the law is not and should not be applied retroactively. In addition to this is the presence of RA No. 6646, wherein it was stated that only registered candidates running for the same position as the nuisance candidate can file a petition under Section 69 of the OEC. Lastly, De Alban also questioned the constitutionality of the last phrase of Section 69 of the OEC, claiming that it allegedly violated the due process clause for lack of comprehensible standards and infringed upon the right of suffrage and the equal protection clause for being subjective and arbitrary. The Office of the Solicitor General pointed out that the COMELEC declared De Alban a nuisance candidate because of his lack of financial capacity and the absence of political machinery in terms of organizational support to wage a nationwide campaign. ISSUES 1. The petitioner questions the constitutionality of the Commission on Elections’ authority to motu proprio refuse to give due course to or cancel the Certificate of Candidacy (CoC) of a nuisance candidate under Section 69 of the Omnibus Election Code (OEC). 2. Whether or not the COMELEC committed grave abuse of discretion in cancelling De Alban’s CoC pursuant to its interpretation of the third instance of Section 69 of the Omnibus Election Code (OEC). RULING The petition is partly GRANTED.

2022-2026 Case Digests and Doctrines Page 16 of 128 1. The Constitutionality of COMELEC’s Motu Proprio Authority Under Section 69 of the Omnibus Election Code The Court upholds the constitutionality of the COMELEC’s authority to motu proprio refuse to give due course to or cancel the CoC of a nuisance candidate under Section 69. 2. Whether or not COMELEC Gravely Abused Its Discretion in Cancelling De Alban’s Certificate of Candidacy The Court set aside the COMELEC En Banc’s Resolution dated January 28, 2019, which declared Angelo Castro De Alban a nuisance candidate. The Court established that the COMELEC committed grave abuse of discretion in cancelling De Alban’s CoC pursuant to its interpretation of the law, yet was unable to provide substantial evidence supporting the rationale for its decision. RATIO DECIDENDI 1. The Applicability of COMELEC’s Authority to Motu Proprio on Aspiring Senatorial Candidates In Agujetas v. Court of Appeals, the Court noted that the OEC “has undergone some amendments, basically by the 1987 Constitution, Republic Act No. 6646, otherwise known as ‘The Electoral Reform Law of 1987,’ and RA No. 7166, providing for synchronized national and local elections on May 11, 1992.” With this, the Court claimed that the Omnibus Election Code remains the fundamental law on the subject and that such pieces of legislation are designed to improve the law and achieve the holding of free, orderly, honest, peaceful, and credible elections. Therefore, the Court rejected the petitioner’s interpretation of the provisions for being legally untenable. Such interpretation is contrary to the plain language of the statute and deviates from its true intent and purpose. 2. COMELEC’s Grave Abuse of Discretion The Court ruled that, in determining whether the matters stated in the certificate of candidacy of an aspiring candidate establish that the said candidate is eligible for the position he is seeking, the process should allow both parties to adduce evidence in support of their contentions. However, in this case, the COMELEC Law Department did not adduce substantial supporting evidence and heavily relied on the petitioner’s financial capacity to wage a nationwide election campaign. Moreover, the Court

2022-2026 Case Digests and Doctrines Page 17 of 128 found that the alleged lack of financial capacity was a transparent attempt to shift the burden of proof upon the candidate alone instead of requiring both parties to provide evidence to support their respective claims. G.R. No. 260374 / G.R. No. 260426 Fr. Christian B. Buenafe, Fides M. Lim, Ma. Edeliza P. Hernandez, Celia Lagman Sevilla, Roland C. Vibal, and Josephine Lascano versus Commission on Elections, Ferdinand Romualdez Marcos, Jr., The Senate of the Philippines, represented by the Senate President, The House of Representatives, represented by the Speaker of the House of Representatives/Bonifacio Parabuac Ilagan, Saturnino Cunanan Ocampo, Maria Carolina Pagaduan Araullo, Trinidad Gerilla Repuno, Joanna Kintanar Cariño, Elisa Tita Perez Lubi, Liza Largoza Maza, Danilo Mallari Dela Fueta, Carmencita Mendoza Florentino, Doroteo Cubacub Abaya, Jr., Erlinda Nable Senturias, Sr. Arabella Cammagay Balingao, Sr. Cherry M. Ibardolaza, CSSJB, Sr. Susan Santos Esmile, SFIC, Homar Rubert Roca Dastajo, Polynne Espineda Dira, James Carwyn Candila, and Jonas Angelo Lopena Abadilla vs. Ferdinand Romualdez Marcos, Jr., The Senate of the Philippines, represented by the Senate President, The House of Representatives, represented by the Speaker of the House of Representatives June 28, 2022 DOCTRINE Moral Turpitude Definition: A conviction for failing to file an ITR does not automatically imply moral turpitude. The Supreme Court ruled that such a violation does not intrinsically involve the qualities of baseness, vileness, or depravity required to constitute moral turpitude. Perpetual Disqualification (Omnibus Election Code): To successfully cancel a Certificate of Candidacy (CoC) under Section 78 of the Omnibus Election Code, there must be a deliberate, false representation of a material fact. The Court held that declaring oneself eligible after an ITR conviction does not constitute false representation if the previous court modifying the penalty did not explicitly include the accessory penalty of perpetual disqualification.

2022-2026 Case Digests and Doctrines Page 18 of 128 The Power of the Electorate: The Supreme Court reiterated a foundational democratic principle: "After all, we must submit to this idea, that the true principle of a republic is, that the people should choose whom they please to govern them." It emphasized that popular elections are the ultimate expression of popular will. FACTS On 2 November 2021, petition rs Buenafe, et al. filed before the COMELEC a Petition to Deny Due Course to or Cancel the COC of respondent Marcos, Jr. under Section 78, in relation to Section 74, Article IX of Batas Pambansa Blg. (BP) 881, or the Omnibus Election Code (OEC). Petitioners Buenafe, et al. identified themselves as Filipinos of legal age, registered voters, and officers of various non-government organizations and civic groups. They claim that respondent Marcos, Jr. made false material representations under oath when he filed his COC for President in the 2022 National Elections with the COMELEC. Subsequently, on 20 November 2021, petitioners Ilagan, et al. filed before the COMELEC a Petition for Disqualification of respondent Marcos, Jr. under Section 12, Article I of the OEC.11 Petitioners Ilagan, et al. identified themselves as Filipinos of legal age who are martial law victims and rights advocates. Petitioners Buenafe, et al. and Ilagan et al referred to the same set of criminal cases for the violation of the National Internal Revenue Code of 1997, as amended (1997 NIRC), involving respondent Marcos, Jr. On 27 June 1990, the Special Tax Audit Team (audit team) created by then Commissioner of Internal Revenμ Jose U. Ong (Commissioner Ong) commenced an investigation of the internal revenue tax and estate tax liabilities of the late President Ferdinand E. Marcos, his immediate family, as well as his alleged "associates and cronies."14 The audit sought to determine whether the taxpayer: (1) medical income; (2) filed the required income tax; and (3) made the corresponding tax payment. The audit team submitted its findings to Commissioner Ong, which prompted him to file a letter complaint dated 25 July 1991 with the Secretary of Justice. Decades later, Marcos, Jr. filed his Certificate of Candidacy (COC) for President in the May 2022 National Elections. Two groups of petitioners challenged his candidacy before the Commission on Elections (COMELEC):

2022-2026 Case Digests and Doctrines Page 19 of 128 1. Buenafe, et al. sought to cancel his COC under Section 78 of the Omnibus Election Code (OEC), arguing he committed a "material false representation" when he answered "No" to whether he had ever been found liable for an offense carrying the penalty of disqualification. 2. Ilagan, et al. filed a petition for disqualification under Section 12 of the OEC, arguing his tax conviction was a crime involving moral turpitude. The COMELEC dismissed both petitions. Following the May 9, 2022 elections, Marcos, Jr. won by a majority vote and was proclaimed President. The petitioners elevated the case to the Supreme Court via Certiorari, claiming the COMELEC committed grave abuse of discretion. ISSUES Whether the COMELEC committed grave abuse of discretion amounting to lack or excess of jurisdiction in refusing to cancel the subject COC of Respondent Marcos, Jr. Whether the subject COC of respondent Marcos, Jr. should be cancelled and the respondent declared as not having been a candidate in the 2022 National Elections. RULING The Court ruled that it retained jurisdiction over the pre-election COMELEC resolutions because a formal election contest under the Presidential Electoral Tribunal (PET) had not yet been initiated. On the merits, the Court ruled that Marcos, Jr. did not commit material false representation because the final 1997 CA decision did not explicitly impose imprisonment or perpetual disqualification; hence, relying on the literal text of a judicial decree shows a lack of intent to deceive. Furthermore, the Court ruled that he was not disqualified under Section 12 because a mere failure to file an ITR is a malum prohibitum omission that does not inherently involve moral turpitude, and the accessory penalty of automatic perpetual disqualification under P.D. 1994 could not be retroactively applied or read into a final judgment that had already lapsed into immutability. RATIO DECIDENDI

2022-2026 Case Digests and Doctrines Page 20 of 128 1. Conviction for Failure to File Tax Returns is Not Inherently a Crime Involving Moral Turpitude • The Court reasoned that the mere omission or failure to file an Income Tax Return (ITR) under the National Internal Revenue Code does not inherently involve fraud, deceit, or bad faith. • The Rule: For a crime to involve moral turpitude, it must inherently demonstrate "baseness, vileness, or depravity in the private and social duties which a man owes to his fellow men." • Application: The failure to file an ITR is a violation of a regulatory duty (mala prohibita). It lacks the essential element of inherent vileness or a deliberate fraudulent intent to evade taxes, which distinguishes it from actual tax evasion. Therefore, the conviction does not trigger the automatic disqualification under Section 12 of the Omnibus Election Code (OEC). 2. No Material Misrepresentation Absent an Explicit Judicial Penalty • The Court ruled that a candidate cannot be held guilty of making a material misrepresentation under Section 78 of the OEC if their declaration of eligibility matches the face of their operative criminal conviction. • The Rule: To cancel a Certificate of Candidacy (CoC), the misrepresentation must be a deliberate, conscious distortion of a material fact (intent to deceive). • Application: The Court of Appeals' final modified decision in the candidate's prior tax case omitted the penalty of perpetual disqualification. Whether that omission was a legal error by the appellate court is irrelevant; the candidate was bound only by the dispositive portion of that final judgment. Because the judgment did not explicitly impose perpetual disqualification, the candidate did not lie or intend to deceive the public when declaring under oath that he was eligible to run. 3. Strict Interpretation of Penal and Disqualification Laws • The Court emphasized that provisions concerning the disqualification of candidates must be construed strictly against disqualification and liberally in favor of eligibility.

2022-2026 Case Digests and Doctrines Page 21 of 128 • The Rule: In democratic processes, courts must exercise extreme caution before overturning the choice of the electorate. • Application: The Commission on Elections (COMELEC) cannot expand the scope of a criminal conviction to impose an unstated accessory penalty of disqualification. To do so would expand the law to the detriment of both the candidate's right to seek office and the sovereign right of the people to vote for their chosen leader.

2022-2026 Case Digests and Doctrines Page 22 of 128 G.R. No. 258435 NORMAN CORDERO MARQUEZ, PETITIONER, VS. COMMISSION ON ELECTIONS, RESPONDENT. June 28, 2022 DOCTRINE A candidate cannot be declared a nuisance candidate solely because of a perceived lack of financial resources, political machinery, or popularity. Such factors are not grounds under Section 69 of the Omnibus Election Code. The COMELEC must establish, by substantial evidence, that the candidate falls within one of the statutory grounds for being a nuisance candidate. FACTS On October 1, 2021, Marquez filed a Certificate of Candidacy 3 for Senator in the 2022 National and Local Elections. Acting thereon, the COMELEC Law Department motu proprio filed a petition to declare Marquez as a nuisance candidate, The COMELEC Law Department also allegedly erred in assuming that he is not known in the entire country except in the locality where he resides. On the contrary, he has been actively campaigning all over the Philippines for about five (5) years already. As an advocate of animal welfare and co-founder of Baguio Animal Welfare, Cordillera to the Rest of the Philippines he had the opportunity to travel and attend to countless animal rescue projects, as well as extend free legal assistance in animal cruelty cases nationwide, all in collaboration with established animal welfare groups. As a result of his successful projects and operations, he had been featured several times in various media; his name is ubiquitous in online animal welfare fora. By Resolution 13 dated December 13, 2021, the COMELEC First Division declared Marquez a nuisance candidate and subsequently canceled his COC. 14 It purportedly found nothing in his Answer which proved that he was not a nuisance candidate. 15 He has the burden of proving that he has made himself known well enough nationwide to persuade a sufficient portion of the electorate to support his candidacy within the short span of time during the campaign period. 16 As it was, his bold claims regarding his achievements and supposed popularity have remained unsubstantiated.

2022-2026 Case Digests and Doctrines Page 23 of 128 The COMELEC En Banc denied reconsideration under Resolution19 dated January 3, 2022 Marquez now charges the COMELEC with grave abuse of discretion for declaring him a nuisance candidate. By Resolution 29 dated January 19, 2022, the Court, after due consideration, issued a TRO, enjoining COMELEC from implementing its assailed Resolutions, Thereafter, Marquez sent the Court two Letters dated January 26 and 27, 2022, informing it that the COMELEC "proceeded with the printing of the ballots, without announcing the Final List of Candidates, in a bid to bar candidates [like him] who have secured TROs" from protesting their exclusion therefrom, and that the COMELEC "conveniently misinterpreted the TRO" because it did not construe the TRO as a prohibition from printing ballots. On February 2, 2022, the COMELEC, through the Office of the Solicitor General, filed its Comment36 (with Motion to Lift Temporary Restraining Order) dated January 31, 2022, and asserted that Marquez raised mere errors of judgment allegedly committed by the COMELEC when it declared him a nuisance candidate. Hence, the petition is beyond the ambit of Rule 65. Eventually, the COMELEC filed its Comment dated May 6, 2022 (May 6 Comment), where it maintained that it had no intention to impede, obstruct, or degrade the administration of justice by printing the ballots beginning January 23, 2022. Crucial pre-election activities, including but not limited to the mandatory Pre-election Logic and Accuracy Tests (PreLAT), were entirely dependent on the timely completion of the printing of ballots. It further claimed that it did not commit any belligerent or contumacious act for it merely pursued its actions to avoid frustrating the conduct of orderly elections as ordained by the Constitution. If the target timelines were not faithfully observed, then the whole electoral process would have suffered grave disruptions to the detriment of the electorate. 48 More important, the controversy had supposedly become moot because the ballots and other election-related equipment were already deployed to the various polling precincts in the country as of the filing of the May 6 Comment. Another. The COMELEC unfairly shifted to Marquez the burden of proving his genuine intention to run for office. As the COMELEC itself held, "he who alleges must prove." 67 Thus, it is the COMELEC Law Department which should adduce evidence in support of its petition to declare Marquez a nuisance candidate, not the other way around.

2022-2026 Case Digests and Doctrines Page 24 of 128 ISSUES Whether COMELEC validly declared Marquez a nuisance candidate and canceled his Certificate of Candidacy (COC). RULING ACCORDINGLY, the petition is PARTLY GRANTED. The Resolution dated December 13, 2021 of the COMELEC Second Division in SPA Case No. 21- 056(DC)(MP) and the Resolution dated January 3, 2022 of the COMELEC En Banc are NULLIFIED. The prayer of Marquez for the inclusion of his name in all the official ballots as a candidate for Senator for the May 2022 National and Local Elections is DECLARED MOOT. The prayer "to make the COMELEC suffer the pain of contempt of Court" because it "brazenly and contumaciously exhibited contempt" and "[was] bold enough to defy the Court" in proceeding with its election preparations despite the Court's issuance of a TRO is DENIED. RATIO DECIDENDI While the COMELEC cannot be faulted for zealously scrutinizing the qualifications of candidates for elective posts, it is reminded to be more circumspect in the pursuit of its mandate under the Constitution and the law. The Supreme Court held that the COMELEC gravely abused its discretion in declaring Marquez a nuisance candidate because it relied solely on his alleged lack of popularity, financial resources, and political machinery—grounds not found in Section 69 of the Omnibus Election Code. The Court ruled that a candidate may be declared a nuisance only upon substantial evidence of the statutory grounds. Otherwise, doing so would impose an unconstitutional property qualification and unduly restrict the right to seek public office.

2022-2026 Case Digests and Doctrines Page 25 of 128 G.R. No. 247645 Liberal Party, represented by its President, Francis N. Pangilinan, and/or Its Secretary General, Jose Christopher Y. Belmonte vs. Commission on Elections and Nacionalista Party, represented by its President, Manuel B. Villar, and/or its Secretary General, Alan Peter Cayetano July 26, 2022 DOCTRINE The Commission on Elections’ constitutional power to enforce and administer all laws and regulations relative to the conduct of an election includes the power to issue rules and regulations on the accreditation of political parties. This Court will not encroach upon such rule-making power unless it is shown that the rules and regulations issued contravene the Constitution and existing laws. FACTS The Commission on Elections (COMELEC) issued Resolution No. 10514, which established the guidelines for the accreditation of the dominant majority party, dominant minority party, ten (10) major national parties, and two (2) major local parties for the May 13, 2019 National and Local Elections. The Liberal Party filed a Petition for Accreditation as the dominant minority party. COMELEC En Banc, through Resolution No. 10538 dated May 8, 2019, denied the petition and accredited the Nacionalista Party as the dominant minority party. Aggrieved, the Liberal Party filed a Petition for Certiorari under Rule 64 in relation to Rule 65, assailing COMELEC Resolution No. 10538. It prayed that the Resolution be annulled and set aside and that the Court establish clear guidelines for the recognition and accreditation of the dominant minority party. ISSUE Whether the Commission on Elections committed grave abuse of discretion in denying the Liberal Party’s Petition for Accreditation as the dominant minority party for the May 13, 2019 National and Local Elections.

2022-2026 Case Digests and Doctrines Page 26 of 128 RULING No. The Supreme Court DISMISSED the Petition for Certiorari and AFFIRMED COMELEC Resolution No. 10538. RATIO DECIDENDI The Court held that ”[t]he Commission on Elections’ constitutional power to enforce and administer all laws and regulations relative to the conduct of an election includes the power to issue rules and regulations on the accreditation of political parties.” It further ruled that ”[t]his Court will not encroach upon such rule-making power unless it is shown that the rules and regulations issued contravene the Constitution and existing laws.” The Court found that the criteria adopted by COMELEC in Resolution Nos. 10514 and 10538 were consistent with Section 26 of Republic Act No. 7166, as amended. The use of a weighted average system and assignment of points to determine the dominant majority and dominant minority parties was a valid exercise of COMELEC’s rule- making authority. The Court likewise held that the petition had become moot because the May 2019 National and Local Elections had already been concluded. Nevertheless, it resolved the issues to guide future elections and held that COMELEC did not exceed its rule- making powers. To impose additional criteria for accreditation “would be an unbecoming and presumptive encroachment on the rule-making powers” of COMELEC.

2022-2026 Case Digests and Doctrines Page 27 of 128 G.R. No. 258456 GIORGIDI B. AGGABAO and AMELITA S. NAVARRO Versus COMMISSION ON ELECTIONS (COMELEC) and LAW DEPARTMENT July 26, 2022 DOCTRINE When conflicting claims of party nomination arise, the COMELEC is required to exercise its quasi-judicial powers by conducting proper proceedings, including notice and hearing, to determine the valid nominee. It cannot rely solely on the apparent regularity of documents or summarily apply rules without resolving the factual controversy. Failure to do so constitutes grave abuse of discretion and a violation of due process. - COMELEC’s ministerial duty to receive COCs ends once a dispute arises; thereafter, it must adjudicate the controversy. - Administrative and quasi-judicial bodies must observe due process, particularly the requirements of notice of hearing, in resolving election- related disputes, - Substitution of candidates is not allowed for independent candidates, but such determination mist be based on a properly resolved finding of party affiliation. FACTS The case arose when petitioners Giorgidi B. Aggabao and Amelita Navarro brought upon Petition for Certiorari before the court seeking to nullify the documents issued by the respondent, COMELEC and its Law Department; declaring Navarro as an independent candidate, denying Aggabaos COC as substitute candidate for Navarro, and denying Aggabao’s Motion for Reconsideration. Navarro initially filed her Certificate of Candidacy (COC) for Mayor of Santiago City, Isabela under Partido Rportma, supported by a Certificate of Nomination and Acceptance (CONA) signed by party chairman, Senator Panfilo Lacson. Shortly thereafter, another individual named Christopher Ayson also filed his Certificate of Candidacy (COC) for the same position, likewise claiming nomination from the same party and presenting his own CONA signed by Senator Lacson.

2022-2026 Case Digests and Doctrines Page 28 of 128 Senator Lacson later issued a formal letter to COMELEC’s Law Department disowning Ayson’s CONA and affirming that Navarro was the party’s official candidate, further stressing that the party did not issue any nomination to Ayson. Senator Lacson likewise requested immediate action on the matter and updating the list of candidates respectively. On November 9, 2021, Navarro withdrew her mayoralty candidacy and decided to run for vice mayor. Designating Aggabao as the substitute Mayoralty candidate of the party. Despite these developments, the COMELEC Law Department declared Navarro an independent candidate, reasoning that the party had supposedly nominated more than one candidate for the same position (sNavarro and Ayson), which is prohibited under election rules. Consequently, because Navarro was treated as an independent candidate, Aggabao’s substitution was denied, since substitution is not allowed for independent candidates. COMELEC maintained this position in subsequent issuances, excluded Aggabao from the official list of mayoralty candidates, and denied his motion for reconsideration. Aggrieved, petitioners elevated the matter to the Supreme Court, alleging that COMELEC acted with grave abuse of discretion, particularly in ignoring the party’s official certification and failing to properly resolve the conflict regarding the valid party nominee. ISSUE 1. W/N the COMELEC and its Law Department committed grave abuse of discretion in declaring Navarro an independent candidate. 2. W/N COMELEC denied due process on Aggabao’s substitution as candidate despite the party’s disavowal of the rival candidate’s CONA, without conducting proper proceedings. RULING Petition was declared moot due to the completion of the elections. However: 1. YES. COMELEC and its Law Department committed grave abuse of discretion in declaring Navarro an independent candidate. It failed to properly determine the validity of the conflicting CONAs and instead 2. YES. COMELEC denied due process. It should have exercised its quasi-judicial powers by conducting a hearing, receiving evidence, and resolving which

2022-2026 Case Digests and Doctrines Page 29 of 128 candidate was the legitimate party nominee. Its failure to do so, and its reliance solely on its Law Department’s recommendation, deprived petitioners of due process. RATIO DECIDENDI The Court held that COMELEC gravely abused its discretion when it declared Navarro an independent candidate and denied Aggabao’s substitution without first resolving the controversy arising from conflicting CONAs through proper proceedings. While the COMELEC initially acted within its ministerial duty in accepting the COCs and CONAs, a justiciable controversy arose when the Partido Reporma chairman formally disavowed the authenticity of Ayson’s CONA and asserted Navarro as the party’s official candidate. At this point, the COMELEC was no longer performing a purely administrative function but was duty-bound to exercise its quasi-judicial powers, which required it to conduct a hearing, receive evidence, and determine the true party nominee. Guided by jurisprudence such as Francisco v. COMELEC, Baytan v. COMELEC, Engle v. COMELEC, and Cerafica v. COMELEC, the Court emphasized that when election disputes involve conflicting factual claims, COMELEC must observe due process, including notice and hearing, and resolve the matter through its Divisions before elevating it en banc. Instead, COMELEC summarily applied the rule on multiple nominations and relied solely on its Law Department’s recommendation, without investigating the validity of the competing CONAs or affording the parties an opportunity to be heard. This shortcut procedure violated due process, as it failed to properly resolve a material factual issue that directly affected the candidates’ status and rights. Consequently, the erroneous declaration of Navarro as an independent candidate led to the improper denial of Aggabao’s substitution, since substitution is not allowed for independent candidates. Such failure to discharge its adjudicative duty in the face of a clear controversy constituted grave abuse of discretion amounting to lack or excess of jurisdiction. Hence, COMELEC must transition from its ministerial role to its quasi-judicial function upon the emergence of a genuine dispute, and its failure to resolve such dispute through proper proceedings and due process renders its actions void for grave abuse of discretion.

2022-2026 Case Digests and Doctrines Page 30 of 128 G.R. No. 258448 Wilson Caritero Amad vs. Commission on Elections July 5, 2022 DOCTRINE To recount, the COMELEC, in its comment, argued that the conduct of the May 2022 NLE rendered Amad's petition moot and academic, and should therefore be dismissed. Notably, the ruling of the Court in Marquez v. Commission on Elections (Marquez case) is instructive vis-à-vis the issue of mootness. In the Marquez case, which involves similar circumstances to the present case, the COMELEC En Banc, in its Resolution dated January 23, 2019, cancelled the COC of Norman Cordero Marquez (Marquez) on the ground that he is a nuisance candidate. Marquez elevated his case before the Court, but before the Court could render a decision, the NLE had been concluded. In giving due course to Marquez's petition despite its being moot with the conclusion of the NLE, the Court explained that it may exercise jurisdiction even over moot issues, if it finds that the case is capable of repetition, yet evading review, to wit: The Court is well aware that the May 13, 2019 national and local elections have concluded, with the proclamation of the top 12 candidates receiving the highest number of votes as senators-elect. This development would ordinarily result in the dismissal of the case on the ground of mootness. Since a judgment in one party's (i.e., Marquez) favor will not serve any useful purpose nor have any practical legal effect because, in the nature of things, it cannot be enforced, the Court would normally decline jurisdiction over it. FACTS OF THE CASE Amad filed his Certificate of Candidacy (COC)4 for Vice President for the May 9, 2022 National and Local Elections (NLE). Thereafter, the COMELEC filed a Petition5 dated October 11, 2021 entitled "In Re: Motu Proprio Petition to Declare Wilson Caritero Amad as Nuisance Candidate," docketed as SPA No. 21-057 (DC)(MP) (the Nuisance Petition). In the Nuisance Petition, the COMELEC averred, among others, that: (1) Amad does not appear to have a genuine intention to run for public office; (2) he does not have a nationwide network of supporters; (3) he is not personally capable of persuading a

2022-2026 Case Digests and Doctrines Page 31 of 128 substantial number of voters from different parts of the country; and (4) he is not virtually known to the entire country except possibly in the locality where he resides. The COMELEC likewise made much of the fact that in Amad's COC, he stated that he was running as an independent candidate with no political party to support him. On February 2, 2022, the COMELEC filed its Comment, where it primarily argued that: (2) Amad failed to prove that he possesses a bona fide intention to run for national office in the May 2022 NLE. Relevantly, on March 11, 2022, the COMELEC filed another Comment, where it manifested, among others, that before the issuance of the TRO, the COMELEC had already commenced several pre-election activities, including the preparation of the printing of the official ballots. In particular, the COMELEC stated that on January 9, 2022, the generation of the final ballot face templates had already begun, while the loading of the finalized list of candidates in the COMELEC's Election Management System and the subsequent generation of the Serialized Machine-Readable Official Ballots were done on January 15, 2022. The COMELEC further manifested that on January 19, 2022, the COMELEC had already commenced the configuration of the Secure Digital cards for use in the Vote-Counting Machines and that starting January 23, 2022, the COMELEC already began printing the serialized ballots. Thus, with the foregoing manifestations, the COMELEC argued that the case had already been moot and academic, and should be dismissed. ISSUES Whether or not petitioner Wilson Caritero Amad is a nuisance candidate. RULING The petition is partly meritorious. RATIO DECIDENDI To recount, the COMELEC, in its comment, argued that the conduct of the May 2022 NLE rendered Amad's petition moot and academic, and should therefore be

2022-2026 Case Digests and Doctrines Page 32 of 128 dismissed. Notably, the ruling of the Court in Marquez v. Commission on Elections[37] (Marquez case) is instructive vis-à-vis the issue of mootness. In the Marquez case, which involves similar circumstances to the present case, the COMELEC En Banc, in its Resolution dated January 23, 2019, cancelled the COC of Norman Cordero Marquez (Marquez) on the ground that he is a nuisance candidate. Marquez elevated his case before the Court, but before the Court could render a decision, the NLE had been concluded. In giving due course to Marquez's petition despite its being moot with the conclusion of the NLE, the Court explained that it may exercise jurisdiction even over moot issues, if it finds that the case is capable of repetition, yet evading review, to wit: The Court is well aware that the May 13, 2019 national and local elections have concluded, with the proclamation of the top 12 candidates receiving the highest number of votes as senators-elect. This development would ordinarily result in the dismissal of the case on the ground of mootness. Since a judgment in one party's (i.e., Marquez) favor will not serve any useful purpose nor have any practical legal effect because, in the nature of things, it cannot be enforced, the Court would normally decline jurisdiction over it.

2022-2026 Case Digests and Doctrines Page 33 of 128 G.R. No. 257453 MARIZ LINDSEY TAN GANA-CARAIT Y VILLEGAS, VS. COMMISSION ON ELECTIONS, ROMMEL MITRA LIM, AND DOMINIC P. NUÑEZ August 9, 2022 DOCTRINE In Treyes v. Larlar, the Court so holds and firmly clarifies that procedural rules must always yield to substantive law. The COMELEC Rules of Procedure do not and should not have the power to overpower or restrict the substantive right granted by the Constitution and the Rules of Court to obtain judicial review of COMELEC decisions within the prescribed period. FACTS OF THE CASE On October 17, 2018, Mariz Lindsey Tan Gana-Carait, the petitioner, filed her CoC as Member of Sangguniang Panlungsod of the Lone District of Biñan, Laguna, for the 13 May 2019 National and Local Elections. On October 22, 2018, respondents Rommel Mitra Lim and Dominic P. Nuñez challenged her candidacy, claiming that the petitioner acquired United States (US) citizenship and sought election to public office without making a personal and sworn renunciation of any and all foreign citizenship before the petitioner filed her CoC. The petitioner, Gana-Carait responded to both petitions made by Lim and Nuñez, arguing that she was a dual citizen by birth, therefore making her out of R.A No. 9225’s scope. The COMELEC First Division ruled that Gana-Carait has dual citizenship and that she acquired her US citizenship through naturalization, their basis being Gana-Carait being born to a Filipino father and an American mother, and Consular Report of Birth Abroad (CRBA) and a US passport that’s been used for traveling between the Philippines and the United States. Consequently, the COMELEC cancelled her CoC for making a material misinterpretation regarding her eligibility for public office. On March 5, 2019, Gana-Carait filed for a Motion for Partial Reconsideration, which was denied by the COMELEC En Banc. Hence, she then elevated the case to the Supreme Court and filed a petition for certiorari under Rule 64, in relation to Rule 65. ISSUES

2022-2026 Case Digests and Doctrines Page 34 of 128 Whether or not the petitioner, Mariz Lindsey Tan Gana-Carait, is a US citizen by birth or by naturalization in relation to her eligibility to run for public office. RULING The Petition for Certiorari is GRANTED. The Court ruled that the petitioner is a dual citizen by birth, not by naturalization. This makes the respondent not part of R.A No. 9225’s jurisdiction regarding requiring the petitioner to take an oath of allegiance and the personal renunciation of foreign citizenship. Therefore, any deliberate representation of false material in her CoC is set aside, which makes her eligible to run for public office. Furthermore, the Court has also ruled that COMELEC committed grave abuse of discretion in cancelling her CoC, making the Resolutions released, cancelled and set aside. RATIO DECIDENDI The Court ruled that R.A No. 9225’s jurisdiction is limited to natural-born Filipinos who became foreign citizens through naturalization only, and not to dual citizens by birth. This ruling was based on the presence of the petitioner’s Consular Report of Birth Abroad (CRBA), which cemented the fact that the petitioner acquired US citizenship at birth, not through any act of naturalization.

2022-2026 Case Digests and Doctrines Page 35 of 128 2023 Case Digests

2022-2026 Case Digests and Doctrines Page 36 of 128 G.R. No. 255509 Edwin D. Rodriguez and Michael T. Defensor vs. Commission on Elections, Maria Josefina G. Belmonte, Gian Carlo G. Sotto, Wilfredo B. Revillame, and Elizabeth A. Delarmente January 10, 2023 DOCTRINE Any complaint that charges the election offense of vote buying must be supported by credible evidence that substantiates the elements of the offense. General averments of vote-buying, when accompanied by uncorroborated video clips and screenshots from such video clips, will be adjudged as mere speculation because they cannot substitute for proof required to establish probable cause. FACTS OF THE CASE Petitioners Edwin D. Rodriguez and Michael T. Defensor filed a Petition for Certiorari under Rule 64 of the Rules of Court seeking to annul and set aside Resolution No. 10625 dated November 14, 2019 and Minute Resolution No. 20-0268-14 dated June 17, 2020 of the Commission on Elections (COMELEC) En Banc in E.O. Case No. 19-199. Petitioners charged respondents Maria Josefina G. Belmonte, Gian Carlo G. Sotto, Wilfredo B. Revillame, and Elizabeth A. Delarmente with vote buying during a political rally held on May 11, 2019. They alleged that Revillame distributed money to the audience while the candidates were present. To support their allegations, petitioners submitted video clips, screenshots, and photographs. The COMELEC Law Department recommended the dismissal of the complaint for lack of probable cause. It found that the allegations were based on general averments and were supported only by uncorroborated video clips and screenshots, without affidavits from the alleged vote recipients or witnesses. The COMELEC En Banc adopted the recommendation and dismissed the complaint. Petitioners’ motion for reconsideration was likewise denied.

2022-2026 Case Digests and Doctrines Page 37 of 128 ISSUE Whether the COMELEC En Banc committed grave abuse of discretion in dismissing the Complaint Affidavit for vote buying for lack of probable cause. RULING No. The Supreme Court DISMISSED the petition and AFFIRMED Resolution No. 10625 dated November 14, 2019 and Minute Resolution No. 20-0268-14 of the COMELEC En Banc. RATIO DECIDENDI The Court held that “Any complaint that charges the election offense of vote buying must be supported by credible evidence that substantiates the elements of the offense.” It emphasized that “General averments of votebuying, when accompanied by uncorroborated video clips and screenshots from such video clips, will be adjudged as mere speculation because they cannot substitute for proof required to establish probable cause.” The Court found that petitioners failed to submit affidavits of the alleged vote recipients or witnesses who could establish that money was given to induce anyone to vote for or against a candidate. The submitted video clips and photographs, standing alone, did not establish the essential elements of vote buying. The COMELEC did not commit grave abuse of discretion in finding that probable cause was absent.

2022-2026 Case Digests and Doctrines Page 38 of 128 G.R. No. 263061 GLENDA BURAY ECLEO, PETITIONER, VS. COMMISSION ON ELECTIONS, RESPONDENT. January 10, 2023 DOCTRINE The right to speedy disposition of cases extends to administrative and quasi-judicial proceedings, including COMELEC preliminary investigations. When the government fails to justify an inordinate delay, and such delay prejudices the respondent, the proceedings may be dismissed for violating Article III, Section 16 of the Constitution. FACTS OF THE CASE This is a Petition for Certiorari under Rule 64 with a prayer for injunctive relief filed by Glenda Buray Ecleo (Ecleo), assailing Resolution No. 21-0424-29 (assailed Resolution),2 dated June 23, 2021, issued by the Commission on Elections (COMELEC) En Banc, in E.O. Case No. 14-598 entitled Commission on Elections, as represented by the Campaign Finance Unit, vs. Glenda Buray Ecleo, that directed the COMELEC Law Department to file an Information against her. Petitioner Ecleo, a member of Lakas-Kampi party, was a candidate for Governor of Dinagat Islands during the 2010 elections. 3 She won and subsequently ran during the 2013 elections, where she was re-elected for her second term of office. On June 8, 2010, Ecleo filed her Statement of Contributions and Expenditures (SOCE),5 following the elections, as required by law. On December 13, 2014, the COMELEC, represented by the Campaign Finance Unit (CFU), filed a Complaint motu proprio against Ecleo with the COMELEC Law Department for an alleged violation of Section 100, m relation to Section 262 of the Omnibus Election Code. The Complaint alleged that Ecleo exceeded the expenditure limit provided by law for campaign spending, in violation of Section 13 ofRepublic Act No. 7166 (R.A. 7166), 8 which allows a candidate, other than for presidency and vice presidency, to spend an amount of P3.00 for every voter currently registered in the constituency where he/she filed his certificate of candidacy.

2022-2026 Case Digests and Doctrines Page 39 of 128 At the time of the 2010 elections, Dinagat Islands had 70,353 registered voters, and Ecleo was authorized to spend P3.00 on each of them. 10 Thus, Ecleo's allowable expenditure limit as provided by law was P211,059.00. 11 However, based on her SOCE, Ecleo spent P230,000.00 in the 2010 election, exceeding the limit by Pl8,941.00, or 8.97% above the allowable threshold. Ecleo vehemently denied the allegations against her, and maintained that she is not guilty of overspending. 14 She asserted that she did not even have to campaign hard in order to win the elections, as demonstrated by her landslide victory over her "unheard-of' opponent and her subsequent re-election to the same position. Ecleo also claimed that her secretary, who prepared the SOCE, merely surmised the amounts as she was not in possession of the receipts at the time. 17 Moreover, she alleged that her SOCE is patently erroneous because it contained unsubstantiated amounts. On June 23, 2021, the COMELEC En Banc issued the assailed Resolution, adopting the recommendation of the Law Department to file an Information against Ecleo for violation of Section 100, in relation to Section 262 of the Omnibus Election Code. Hence, on August 12, 2022, Ecleo filed this Petition for Certiorari under Rule 64 before the Court, alleging grave abuse of discretion amounting to lack or excess of jurisdiction on the part of the COMELEC En Banc for (1) issuing the assailed Resolution seven years from the time of the filing of the complaint, resulting in inordinate and gross delay; (2) refusing to consider that the complaint is moot and academic, considering that she has not only finished her term, but has in fact been re- elected and finished her second term as Governor of Dinagat Islands; and (3) considering the inherently defective SOCE which formed the basis for the complaint. Moreover, Ecleo also prays for the grant of injunctive relief in order to prevent its execution. ISSUES 1. Did the COMELEC gravely abuse its discretion when it issued the assailed Resolution seven years from the time of the filing of the complaint amounting to inordinate delay? 2. Did the COMELEC gravely abuse its discretion when it refused to consider the complaint as moot and academic?

2022-2026 Case Digests and Doctrines Page 40 of 128 3. Did the COMELEC gravely abuse its discretion when it considered the inherently defective SOCE, which formed the basis for the complaint? RULING The Court finds that the COMELEC is guilty of inordinate delay in the conduct of its preliminary investigation against Ecleo, and violating its own rules of procedure. It is apparent that the CO MEL EC' s act of issuing the assailed Resolution against Ecleo seven years after the filing of the complaint is tainted with grave abuse of discretion. Consequently, it is superfluous to discuss the other issues raised. The Court grants the Rule 64 Petition for Certiorari filed by Ecleo, and nullifies the assailed Resolution issued by the COMELEC directing the Law Department to file an Infonnation against Ecleo for violation of Section 100, in relation to Section 262, of the Omnibus Election Code. WHEREFORE, the Petition for Certiorari is GRANTED. The assailed Resolution No. 21-0424-29, dated June 23, 2021, of the Commission on Elections in E.O. Case No. 14- 598 is NULLIFIED, having been issued with grave abuse of discretion. E.O. Case No. 14-598 against the petitioner Glenda Buray Ecleo is DISMISSED. RATIO DECIDENDI The COMELEC committed grave abuse of discretion when it took seven years to resolve a simple election offense complaint without adequate justification. Applying the Cagang balancing test, the Supreme Court held that the delay was inordinate, unjustified, and prejudicial to the respondent, thereby violating her constitutional right to the speedy disposition of cases under Article III, Section 16 of the Constitution. As a result, the Resolution ordering the filing of an Information was nullified and the complaint dismissed.

2022-2026 Case Digests and Doctrines Page 41 of 128 G.R. No. 257610 Glen Quintos Albano vs. Commission on Elections January 24, 2023 DOCTRINE Congress may prescribe qualifications for party‑list nominees under the “as provided by law” clause, but such power is limited by the equal protection clause; thus, classifications must meet the test in People v. Cayat and Victoriano v. Elizalde, and under the rational basis standard, a disqualification based solely on a prior electoral loss is unconstitutional for being arbitrary and lacking any rational relation to a legitimate state interest. FACTS OF THE CASE Herein, a consolidated petition for certiorari and prohibition by Glen Quintos Alabano – 2nd Nominee (TGP Party-list) and Catalina G. Leonen-Pizarro – 1st Nominee (ABS Party-list). Both petitioners sought to run as party-list nominees in the 2022 elections. However, they were barred from running because they had lost in the immediately preceding elections (2019). Their disqualification was based on Sec. 8, of RA 7941 and Sections 5(d) and 10, COMELEC Resolution No. 10717. The provisions prohibited the inclusions of party-list nominees of (1) candidates for elective office and (2) persons who lost in the immediate preceding elections. Hence, petitioners filed certiorari and prohibition, claiming the provisions are unconstitutional and violative of the equal protection clause under the 1987 Constitution. ISSUE 1. Whether Congress may add qualifications for party‑list nominees beyond those stated in the Constitution. 2. Whether the disqualification of losing candidates violates the Equal Protection Clause. RULING Petition was partly granted.

2022-2026 Case Digests and Doctrines Page 42 of 128 1. YES. Congress may validly prescribe additional qualifications for party‑list representatives because the Constitution authorizes it to do so under the clause “as provided by law. Provided that it must not violate the equal protection clause of the Constitution. 2. YES. The disqualification of persons who lost in the immediately preceding election is unconstitutional for violating the equal protection clause, as it creates an arbitrary classification unsupported by any rational basis. Further, the Court upheld the prohibition against a person being (a) a candidate for another elective office in the same election and (b) a party-list nominee. This is valid as it prevents dual candidacy and conflicting representation. RATIO DECIDENDI The Court ruled that the disqualification of candidates who lost in the immediately preceding election violates equal protection because it creates an arbitrary classification that fails the standards laid down in People v. Cayat and Victoriano v. Elizalde Rope Workers’ Union, which require that classifications must rest on substantial distinctions and be reasonable, not arbitrary, as reinforced in Ang Ladlad LGBT Party v. COMELEC. The law unreasonably distinguishes losing candidates from those who won or did not run, despite there being no substantial difference between them. Applying the rational basis test under Samahan ng mga Progresibong Kabataan v. Quezon City, and acknowledging under Quinto v. COMELEC, Pamatong v. COMELEC, and Marquez v. COMELEC that the right to run for public office is not fundamental, the Court nevertheless held that the classification has no reasonable relation to the purpose of preventing abuse of the party-list system, contrary to British American Tobacco v. Camacho, and lacks adequate justification under City of Manila v. Laguio, thus rendering it unconstitutional for violating both equal protection and substantive due process.

2022-2026 Case Digests and Doctrines Page 43 of 128 G.R. No. 261344 Frank Ong Sibuma vs. Commission on Elections, Alma L. Panelo, and Stefanie Ann Eriguel Calongcagon January 24, 2023 DOCTRINE In Mitra v. Commission on Elections,[75] the Court, confronted with a similar issue on false representation on residence requirement in a CoC, set aside the cancellation of the CoC of petitioner therein for failure of the COMELEC "to critically consider whether [he] deliberately attempted to mislead, misinform or hide a fact that would otherwise render him ineligible for the position of Governor of Palawan."[76] The Court underscored that without such finding, a cancellation of CoC cannot be sustained. Indeed, the lack of findings of intent on the part of Sibuma to deceive the electorate of the Municipality of Agoo, La Union taints the issuance of the assailed Resolution cancelling his CoC, as well as the Writ of Execution nullifying his proclamation, with grave abuse of discretion amounting to lack or excess of jurisdiction.[77] It bears further underscoring, that the cancellation of a certificate of candidacy is "not based on the lack of qualifications but on a finding that the candidate made a material representation that is false, which may relate to the qualifications required of the public office he [or] she is running for."[78] This reiterates the indispensability of the element of intent to deceive the electorate in a Section 78 petition, the lack of which gives rise to a presumption of good faith in favor of a candidate's declaration in his or her CoC under oath. As Associate Justice Alfredo Benjamin S. Caguioa comprehensively underscored in his Dissenting Opinion in Villamor v. Commission on Elections,[79]Section 74 only requires that the facts declared in the CoC be true to the best of the candidate's knowledge. FACTS OF THE CASE Alma L. Panelo (Panelo) filed a Petition to Deny Due Course [to] or Cancel [a] Certificate of Candidacy[8] dated November 2, 2021 under Section 78 of the Omnibus Election Code of the Philippines[9] (OEC) against Sibuma. Panelo averred that Sibuma committed a material misrepresentation when he stated in his CoC that "he will be a resident of Brgy. Sta. Barbara, Agoo, La Union for 1 year and 3 months on the day before the May 9, 2022 Elections"[10] because "in truth and in fact he is a resident of Zone 2, Purok 9, San Eugenio, Aringay, La Union."[11]

2022-2026 Case Digests and Doctrines Page 44 of 128 On May 13, 2022, the COMELEC Second Division issued the assailed Resolution[27] granting Panelo's petition to deny clue course to or cancel Sibuma's CoC and ruled that Sibuma committed material misrepresentation in his CoC relating to his residency. All respondents pray that the TRO and SQA Order issued by the Court on July 5, 2022 be lifted on the ground that the acts sought to be enjoined from had already become fait accompli.[56] They aver that pursuant to the assailed Writ of Execution dated June 29, 2022, the Municipal Board of Canvassers of Agoo, La Union reconvened on July 5, 2022. On the same day, it annulled Sibuma's proclamation and, thereafter, proclaimed private respondent Eriguel in his stead as the duly elected Mayor of Agoo, La Union. ISSUES Whether the COMELEC Second Division gravely abused its discretion when it ordered the cancellation of Sibuma's CoC and the nullification of his proclamation as the duly elected Mayor of Agoo, La Union. RULING The Court grants the petition. RATIO DECIDENDI Respondent [COMELEC] committed grave abuse of discretion amounting to lack or excess of jurisdiction when it gave due course to the Petition to Deny Due Course and/or Cancel COC of [Sibuma], even if the said Petition was clearly filed out of time[;] Respondent [COMELEC] committed grave abuse of discretion amounting to lack or excess of jurisdiction when it denied [Sibuma's] right to appeal to the [COMELEC] En Banc the assailed Resolution even if [he] timely filed [his] Motion for Reconsideration[;] Respondent [COMELEC] committed grave abuse of discretion amounting to lack or excess of jurisdiction when it prematurely issued the assailed Writ of Execution.[51]

2022-2026 Case Digests and Doctrines Page 45 of 128 G.R. No. 262622 PRYDE HENRY A. TEVES, PETITIONER, VS. COMMISSION ON ELECTIONS, ROEL R. DEGAMO, AND GREGO "RUEL" DEGAMO RESPONDENTS. G.R. No. 262682 GREGO "RUEL" G. DEGAMO, PETITIONER, VS. COMMISSION ON ELECTIONS AND ROEL R. DEGAMO, RESPONDENTS. February 14, 2023 DOCTRINE A candidate may be declared a nuisance candidate under Section 69 of the Omnibus Election Code when the Certificate of Candidacy was filed to cause confusion among voters by the similarity of names of registered candidates or by other circumstances or acts which clearly demonstrate that the candidate has no bona fide intention to run for the office. The votes obtained by a declared nuisance candidate must be credited in favor of the legitimate candidate with a confusingly similar name, whether the election is conducted manually or through automation, and even if the declaration of nuisance candidacy becomes final only after the elections. In a petition for declaration of a nuisance candidate, the only real parties in interest are the alleged nuisance candidate and the legitimate candidate whose name is confusingly similar; other candidates are mere observers whose non-impleadment does not violate due process. In a single-slot office, the votes for the nuisance candidate are simply added to the legitimate candidate's total. In a multi-slot office, the COMELEC must inspect the ballots to ensure no double counting occurs where a voter may have voted for both the nuisance and legitimate candidates on the same ballot. FACTS On October 7, 2021, Roel R. Degamo (Roel) filed his Certificate of Candidacy for Governor of Negros Oriental under the Nacionalista Party. The following day, Ruel filed his Certificate of Candidacy as an independent candidate for the same position. Teves filed his own Certificate of Candidacy to be part of the gubernatorial race. On October 13, 2021, Roel filed a Petition before the COMELEC seeking to declare Ruel as a nuisance candidate. Ruel countered that he has all the qualifications and none of the disqualifications to run for a local elective office such as for the position of governor. Thus, there is no

2022-2026 Case Digests and Doctrines Page 46 of 128 valid reason to cancel or deny due course his Certificate of Candidacy. Ruel claimed that to require him or anyone aspiring to run for a public office to have the "means, influence, and machinery" to wage a campaign is tantamount to imposing a property qualification that is not allowed by the Constitution or any law. The COMELEC Second Division noted that Ruel is known as Ruel Gaudia and it is only recently that he opted to use Ruel Gaudia Degamo. The presence of two "Degamos", one with a name "Roel" and another with the nickname "Ruel" will necessarily confuse the voters and render worthless a vote for a "Degamo" during the appreciation of votes. It also declared that Ruel failed to demonstrate his bona fide intention to run for public office in good faith and that no evidence was presented to show that Ruel is aware of the rigors of a campaign and has acted or is acting in response to these rigors. On May 9, 2022, the electorate of Negros Oriental voted for local and national positions without the final resolution on the issue of whether Ruel is a nuisance candidate. As a result, the name "Ruel Gaudia Degamo" remained on the official ballot as candidate for governor. The results of the election tally resulted in Teves receiving the highest number of votes. Roel and Ruel came in second and third respectively. On the same day of the Elections, Roel filed an Urgent Motion for Early Resolution of the Motion for Reconsideration stating that the resolution of the motion will decisively affect the outcome in the gubernatorial race. On June 20, 2022, Roel filed before this Court a Petition for Mandamus. He imputed that the COMELEC has the clear legal duty to resolve with dispatch the case for declaration of a nuisance candidate and the cancellation of the Certificate of Candidacy. Roel asserted that by its nature, a case for declaration of nuisance candidates was purposely designed to be summary and expeditious. He also highlighted that as per the COMELEC Rules of Procedure and pertinent COMELEC Resolutions, the nuisance proceedings may be resolved with finality within a period of 30-60 days On August 16, 2022, this Court granted the Petition for Mandamus filed by Roel. Then on September 1, 2022, the COMELEC En Banc issued its assailed Resolution denying the Motion for Reconsideration filed by Ruel, Teves claimed in G.R. No. 262622 that the COMELEC En Banc committed grave abuse of discretion when it ruled that Ruel is a nuisance candidate and the votes cast in his favor should be counted in favor of Roel instead. Teves also stated that because of the

2022-2026 Case Digests and Doctrines Page 47 of 128 active and very specific campaign launched against Ruel, the voters cannot be deemed to have been confused about the identity of the two individuals especially since Roel is a well-known public figure in the province. ISSUES Whether the COMELEC committed grave abuse of discretion in declaring Ruel a nuisance candidate and in ordering the crediting of his votes to Roel. Also in question is whether Teves, as the winning candidate who was not impleaded in the nuisance petition, was denied due process. Whether the votes obtained by a nuisance candidate in an automated election system should be credited to the legitimate candidate with a similar name is likewise presented for resolution. RULING In summary, this Court finds that the COMELEC En Banc did not commit grave abuse of discretion in affirming the findings of the COMELEC Second Division. WHEREFORE, premises considered, this Court further RESOLVES to DISMISS the Petitions in G.R. No. 262622 and G.R. No. 262682 due to the absence of grave abuse of discretion committed by the Commission on Elections En Banc in SPA No. 21-085 (DC) dated September 1, 2022. RATIO DECIDENDI The Supreme Court emphasized that election laws must be interpreted in a manner that gives effect to the will of the electorate rather than frustrate it through technicalities. A stray vote is one where the voter’s intention cannot be determined. However, when circumstances clearly show that the voter intended to vote for a legitimate candidate but the ballot contained the name of a nuisance candidate with a similar name, the vote should not be disregarded. The Court reiterated its previous rulings that votes cast for nuisance candidates may be credited to the legitimate candidate when: 1. the nuisance candidate’s name closely resembles the legitimate candidate’s name; 2. the inclusion of the nuisance candidate creates voter confusion; and 3. the true intention of the voters can reasonably be determined.

2022-2026 Case Digests and Doctrines Page 48 of 128 The Court also explained that a petition for certiorari only examines whether COMELEC acted with grave abuse of discretion amounting to lack or excess of jurisdiction. Mere errors of judgment are insufficient grounds for granting the petition.

2022-2026 Case Digests and Doctrines Page 49 of 128 G.R. No. 259354 National Press Club of the Philippines, Automated Election System Watch, and Guardians Brotherhood, Inc. versus. Commission on Elections June 13. 2023 DOCTRINE “Mandamus can be awarded only when the petitioner’s legal right to the performance of the particular act, which is sought to be compelled, is clear and complete.” The duty is ministerial only when its discharge requires neither the exercise of official discretion nor judgment. FACTS OF THE CASE Petitioners National Press Club of the Philippines (NPCP), Automated Election System Watch (AES Watch), and Guardians Brotherhood, Inc. (GBI) filed a Petition for Mandamus praying that the Supreme Court issue a writ of mandamus commanding the Commission on Elections (COMELEC) to: • Implement the use of digital signature for the 2022 National and Local Elections (NLE); and • Disclose critical information and allow access and inspection of the printing of ballots, defective ballots, configuration and preparation of Secure Digital (SD) cards, preparation, testing, and deployment of Vote Counting Machines (VCMs), National Technical Support Center, technical hubs, data centers, and the transmission diagram or data/communications network architecture (collectively, the Election Transparency Activities). Petitioners alleged that they possessed a clear legal right to compel COMELEC to perform these acts pursuant to the Constitution and election laws. COMELEC, on the other hand, argued that the petition had become moot and academic after the successful conduct of the 2022 NLE and that mandamus does not lie because the acts sought to be compelled involve the exercise of discretion and not merely ministerial duties. ISSUE

2022-2026 Case Digests and Doctrines Page 50 of 128 Whether petitioners are entitled to a writ of mandamus compelling COMELEC to implement the use of digital signatures and to disclose critical information and allow access and inspection of the Election Transparency Activities. RULING No. The Supreme Court DISMISSED the Petition for Mandamus. The Court held that although the petition had been rendered moot and academic by the conclusion of the 2022 National and Local Elections, it nevertheless resolved the issues because the case falls under the recognized exceptions to the mootness doctrine, particularly those involving paramount public interest, the formulation of controlling principles, and issues capable of repetition yet evading review. RATIO DECIDENDI The Court ruled that: “Mandamus is an extraordinary writ commanding a person, tribunal, corporation, board, or officer to do an act required to be done, as when they/it unlawfully neglects the performance of an act which the law specifically enjoins as a duty, and there is no other plain, speedy, and adequate remedy in the ordinary course of law.” The Court further explained that: “The duty is ministerial only when its discharge requires neither the exercise of official discretion nor judgment.” For mandamus to lie, the following requisites must concur: 1. The petitioner has a clear legal right to the act demanded 2. It must be the duty of the respondent to perform the act because it is mandated by law 3. The respondent unlawfully neglects the performance of the duty enjoined by law 4. The act to be performed is ministerial, not discretionary 5. There is no appeal or any other plain, speedy, and adequate remedy in the ordinary course of law. Applying these requisites, the Court held that COMELEC cannot be compelled to implement digital signatures in the specific manner demanded by petitioners because the law leaves the manner of implementation to COMELEC’s discretion.

2022-2026 Case Digests and Doctrines Page 51 of 128 The Court also ruled that while election laws require COMELEC to allow observers in activities such as the printing and distribution of ballots and the examination and testing of election equipment, no law specifically requires COMELEC to allow access to its servers, data centers, technical hubs, SD card configuration, or transmission architecture. Hence, these are not ministerial duties enforceable by mandamus.

2022-2026 Case Digests and Doctrines Page 52 of 128 G.R. No. 257427 Florida P. Robes vs. Commission on Elections June 13. 2023 DOCTRINE As can be distilled from the aforementioned deliberations between Rep. Silverio and the Chairperson of the Committee, Congress never intended the lone legislative district of San Jose Del Monte to be left out. In fact, throughout the law's legislative history, the lawmakers were consistent in including the lone legislative district of San Jose Del Monte in the list of the Province of Bulacan's legislative districts. Thus, in breathing life into RA No. 11546, the original intent of the lawmakers, as embodied in HB No. 5866, should be given profuse weight and credence. The intent of the statute is the law itself, as held by the Court in Torres v. Limjap: If a statute is valid, it is to have effect according to the purpose and intent of the lawmaker. The intent is the vital part, the essence of the law, and the primary rule of construction is to ascertain and give effect to that intent. The intention of the legislature in enacting a law is the law itself, and must be enforced when ascertained, although it may not be consistent with the strict letter of the statute. Courts will not follow the letter of a statute when it leads away from the true intent and purpose of the legislature and to conclusions inconsistent with the general purpose of the act. Intent is the spirit which gives life to a legislative enactment. In construing statutes, the proper course is to start out and follow the true intent of the legislature and to adopt that sense which harmonizes best with the context and promotes in the fullest manner the apparent policy and objects of the legislature. FACTS OF THE CASE This Urgent Petition for Mandamus with Prayer for Preliminary Mandatory Injunction (Urgent Petition), Florida P. Robes (petitioner) seeks to compel respondent Commission on Elections (COMELEC) to allocate two seats in the Sangguniang Panlalawigan of the Province of Bulacan in favor of the lone legislative district of San Jose Del Monte. In due course, the COMELEC issued a reply11 to petitioner denying her request.12 The COMELEC ruled that the lone legislative district of San Jose Del Monte is ineligible to have its separate representation in the Sangguniang Panlalawigan because of the following grounds:

2022-2026 Case Digests and Doctrines Page 53 of 128 1. Section 2 of RA No. 9230 only provided the City of San Jose Del Monte its own representative district thereby constituting the City of San Jose Del Monte into a lone legislative district. It did not, in anyway, have the effect of reapportioning the entire Province of Bulacan into several legislative districts; 2. [E]ven in RA No. 11546 — the law which apportioned the entire Province of Bulacan into several legislative districts — the Lone Legislative District of the City of San Jose Del Monte was remarkably eliminated and not mentioned, thereby depriving it of the opportunity of being allocated with its own seats in the Sangguniang Panlalawigan of Bulacan; and 3. [T]here is no provision in RA No. 9230 which expressly gives the City of San Jose Del Monte separate representation in the Sangguniang Panlalawigan of Bulacan.13 (Emphasis supplied.) Aggrieved, petitioner seeks succor via this Urgent Petition,14 imploring the Court to direct the COMELEC to amend Section 6 of Resolution No. 10707. Petitioner supplicates the allocation of two seats in favor of the lone district of San Jose Del Monte in the Sangguniang Panlalawigan of the Province of Bulacan. ISSUES Whether the City of San Jose del Monte, as a lone legislative district of Bulacan province, was entitled to its own representatives in the Sangguniang Panlalawigan by tracing Republic Act No. 11546's legislative history. RULING The lone legislative district of San Jose Del Monte is entitled to its own representatives in the Sangguniang Panlalawigan RATIO DECIDENDI As earlier adumbrated, in 2003, RA No. 9230 accorded the City of San Jose Del Monte its own representative district, constituting the City of San Jose Del Monte as a lone legislative district. Appositely, the legislative history of RA No. 11546 divulges the irrefutable truth that it was indeed the intention of the legislators to reapportion the Province of Bulacan

2022-2026 Case Digests and Doctrines Page 54 of 128 into seven legislative districts, including the lone legislative district of San Jose Del Monte. The explanatory note of House Bill (HB) No. 5866, the precursor of R.A. No. 11546, states that: This bill proposes for the reapportionment of the legislative districts in the Province of Bulacan from the current four (4) to seven (7), with the Constitution providing for in: A legislative district is the basis for the election of a member of the House of Representatives and members of the local legislative body. As such, "representative district" may pertain to either or both the House of Representatives and the Sangguniang Panlalawigan. The COMELEC, therefore, veered away from the exacting provisions of Section 41(b) of RA No. 7160 when it recognized the representation of the lone legislative district of San Jose Del Monte in the House of Representatives, yet concurrently dismissed its consequential significance in the determination of entitlement to representation in the Sangguniang Panlalawigan.

2022-2026 Case Digests and Doctrines Page 55 of 128 G.R. No. 242255 PROVINCE OF SULU, DULY REPRESENTED BY ITS GOVERNOR, ABDUSAKUR A. TAN II versus PHILIPPINE ASSOCIATION OF ISLAMIC ACCOUNTANTS [PAIA], INC., REPRESENTED BY ITS PRESIDENT, AMANODING D. ESMAIL, CPA, ET AL.; GOVERNOR ESMAEL G. MANGUDADATU, ET AL.; AND ALGAMAR A. LATIPH, ET AL.; PETITIONERS-IN-INTERVENTION; VS. HON. SALVADOR C. MEDIALDEA, IN HIS CAPACITY AS EXECUTIVE SECRETARY; HONORABLE EDUARDO M. AÑO, IN HIS CAPACITY AS OFFICER-IN-CHARGE OF THE DEPARTMENT OF INTERIOR AND LOCAL GOVERNMENT; THE HONORABLE SENATE OF THE PHILIPPINES; THE HONORABLE HOUSE OF REPRESENTATIVES; THE HONORABLE COMMISSION ON ELECTIONS; HONORABLE JESUS G. DUREZA, IN HIS CAPACITY AS SECRETARY OF THE OFFICE OF THE PRESIDENTIAL ADVISER ON THE PEACE PROCESS; BANGSAMORO TRANSITION COMMISSION; AND MORO ISLAMIC LIBERATION FRONT September 9, 2024 G.R. No. 243246 PHILIPPINE CONSTITUTION ASSOCIATION [PHILCONSA], PETITIONER, VS. SENATE OF THE PHILIPPINES, REPRESENTED BY SENATE PRESIDENT HONORABLE VICENTE SOTTO; HOUSE OF REPRESENTATIVES, REPRESENTED BY SPEAKER HONORABLE GLORIA MACAPAGAL ARROYO; AND OFFICE OF THE PRESIDENT, REPRESENTED BY EXECUTIVE SECRETARY HONORABLE SALVADOR MEDIALDEA, RESPONDENTS. G.R. No. 243693 CONG. ABDULLAH D. DIMAPORO AND CONG. MOHAMAD KHALID Q. DIMAPORO, PETITIONERS, VS. COMMISSION ON ELECTIONS [COMELEC], AS REPRESENTED BY HON. CHAIRPERSON SHERIFF ABAS, RESPONDENT.

2022-2026 Case Digests and Doctrines Page 56 of 128 DOCTRINE Under Article X, Section 18 of the 1987 Constitution, inclusion in an autonomous region requires the affirmative vote of the individual province, city, or geographic area concerned. A province that votes against inclusion cannot be compelled to become part of an autonomous region based on the collective vote of other areas. The constitutional requirement of plebiscitary consent protects the right of local communities to determine their political status and ensures that autonomy is established through genuine consent of the people. Furthermore, when only a specific provision of a law is found unconstitutional, the remainder of the statute may continue to operate if it can stand independently and still fulfill the legislative purpose. This applies through the doctrine of separability. FACTS OF THE CASE On July 27, 2018, President Rodrigo Roa Duterte signed into law Republic Act No. 11054, otherwise known as the Bangsamoro Organic Law (BOL). The law abolished the Autonomous Region in Muslim Mindanao (ARMM) and established the Bangsamoro Autonomous Region in Muslim Mindanao (BARMM), providing for its governmental structure, powers, and territorial jurisdiction. It also required the conduct of a plebiscite to determine the ratification of the law and the territorial composition of the new autonomous region. Prior to the plebiscite, the Province of Sulu, represented by Governor Abdusakur A. Tan II, filed a petition for Certiorari and Prohibition before the Supreme Court. The Province challenged the constitutionality of several provisions of the Bangsamoro Organic Law, arguing that the law violated the 1987 Constitution by abolishing the ARMM, creating a parliamentary form of regional government, granting powers beyond those authorized by the Constitution, and providing for the inclusion of Sulu in the BARMM despite the constitutional requirement that only provinces, cities, and geographic areas voting favorably in a plebiscite may be included in an autonomous region. Despite the pending petitions, the Commission on Elections proceeded with the Bangsamoro plebiscite on January 21 and February 6, 2019. While the Bangsamoro Organic Law was ratified by the required majority vote in the areas covered by the plebiscite, the voters of the Province of Sulu rejected the law, with a majority voting against its ratification. Nevertheless, Sulu remained included in the BARMM because

2022-2026 Case Digests and Doctrines Page 57 of 128 the former ARMM was treated as a single territorial unit for purposes of determining the overall result of the plebiscite. The petition was later consolidated with other cases questioning the constitutionality of the Bangsamoro Organic Law. Among the issues presented before the Supreme Court was whether the inclusion of Sulu in the BARMM, despite its rejection of the Bangsamoro Organic Law in the plebiscite, violated Article X, Section 18 of the 1987 Constitution, which provides that only the provinces, cities, and geographic areas voting favorably in a plebiscite shall be included in the autonomous region. ISSUES 1. Whether the inclusion of the Province of Sulu in the Bangsamoro Autonomous Region in Muslim Mindanao (BARMM), despite its rejection of the Bangsamoro Organic Law (BOL) during the plebiscite, violated Article X, Section 18 of the 1987 Constitution. 2. Whether Republic Act No. 11054, or the Bangsamoro Organic Law, is unconstitutional for allegedly violating the constitutional provisions on local autonomy, the creation of autonomous regions, and the powers granted to the Bangsamoro government. 3. Whether the Supreme Court may exercise judicial review over the constitutionality of the Bangsamoro Organic Law despite the political nature of the issues involved. RULING ACCORDINGLY, the application for the issuance of a temporary restraining order and/or writ of preliminary injunction in G.R. Nos. 242255 and 243246, and the Motion for Inhibition in G.R. No. 243246 are DENIED for lack of merit. The Petition in G.R. No. 242255 is PARTIALLY GRANTED. Republic Act No. 11054, in so far as it includes petitioner Province of Sulu in the Bangsamoro Autonomous Region, is declared VOID for being UNCONSTITUTIONAL. The Province of Sulu shall not be part of the Bangsamoro Autonomous Region. The Supreme Court partially granted the petition and declared the inclusion of the Province of Sulu in the BARMM unconstitutional.

2022-2026 Case Digests and Doctrines Page 58 of 128 The Court ruled that under Article X, Section 18 of the 1987 Constitution, only the provinces, cities, and geographic areas that vote favorably in a plebiscite shall be included in an autonomous region. Since the people of Sulu voted against the ratification of the Bangsamoro Organic Law, Sulu could not validly become part of the BARMM. However, the Court upheld the constitutionality of the remaining provisions of the Bangsamoro Organic Law. The invalidation was limited only to Sulu's inclusion, and the rest of the law remained effective under the doctrine of separability. The Court also held that the issues raised involved constitutional questions that were within the Court's power to review. The political significance of the Bangsamoro peace process did not prevent judicial examination of whether the law complied with the Constitution. The remaining provisions of Republic Act No. 11054, otherwise known as the Organic Law for the Bangsamoro Autonomous Region in Muslim Mindanao, based on the challenges raised in these petitions, are NOT UNCONSTITUTIONAL. RATIO DECIDENDI

2022-2026 Case Digests and Doctrines Page 59 of 128 G.R. No. 260116 Agnes C. Villanueva v. Commission on Elections July 11, 2023 DOCTRINE Section 261(f) of the Omnibus Election Code penalizes coercion, intimidation, threats, harassment, or undue influence against election officials or employees in the performance of their election functions or duties, regardless of whether such functions are performed during or outside the election period. Further, the constitutional right to the speedy disposition of cases extends to preliminary investigations conducted by the Commission on Elections. Unjustified and inordinate delay in resolving complaints constitutes a violation of due process and warrants the dismissal of the case. FACTS Petitioner Agnes C. Villanueva, then Mayor of Plaridel, Misamis Occidental, requested the reassignment of Municipal Election Officer Amado B. Quiza due to alleged irregularities committed in the conduct of voter registration and the performance of his official functions. Thereafter, petitioner informed the Commission on Elections (COMELEC) that the Municipal Election Office would no longer be allowed to occupy space within the municipal hall. On November 15, 2010, the municipal election office was ordered closed. As a consequence, the COMELEC filed a complaint for violation of Section 261(f) of the Omnibus Election Code (OEC) against petitioner for allegedly coercing, intimidating, and interfering with an election officer in the performance of his election functions and duties. Following preliminary investigation proceedings, the COMELEC En Banc issued resolutions finding probable cause to indict petitioner. Aggrieved, petitioner filed a petition for certiorari before the Supreme Court, contending that: (1) Section 261(f) of the OEC applies only to acts committed during the election period; and (2) the more than eleven-year delay in resolving the complaint violated her constitutional right to the speedy disposition of cases. ISSUES

2022-2026 Case Digests and Doctrines Page 60 of 128 1. Whether Section 261(f) of the Omnibus Election Code applies only during the election period. 2. Whether the delay of more than eleven years in the conduct of the preliminary investigation violated petitioner's constitutional right to the speedy disposition of cases. RULING The Supreme Court held that Section 261(f) of the the Omnibus Election Code is not confined to acts committed during the election period. The Court explained that election functions and duties are not limited to activities undertaken during the election period because election officers perform continuing functions, including voter registration and the maintenance of voters' records, even outside such period. However, the Court ruled that petitioner's constitutional right to the speedy disposition of cases was violated. The COMELEC failed to provide a sufficient justification for the extraordinary delay of more than eleven years in resolving the complaint. Applying the standards laid down in Cagang v. Sandiganbayan, the Court found the delay to be vexatious, capricious, and oppressive. Accordingly, the petition was granted, the assailed COMELEC resolutions were annulled, and the election offense case against petitioner was dismissed. RATIO DECIDENDI The Court ruled that the phrase "election functions or duties" under Section 261(f) of the OEC encompasses all functions legally entrusted to election officials, regardless of whether they are performed during or outside the election period. The absence of any qualifying phrase limiting the application of the provision to the election period indicates the legislative intent to protect election officials at all times while performing election-related functions. Nevertheless, the Court emphasized that the constitutional right to the speedy disposition of cases applies to all judicial, quasi-judicial, and administrative proceedings. In determining whether such right has been violated, courts must consider the length of delay, the reasons for the delay, the assertion of the right by the accused, and the prejudice caused by the delay. In this case, the eleven-year delay in the conduct of the preliminary investigation was unjustified and constituted grave abuse of discretion.

2022-2026 Case Digests and Doctrines Page 61 of 128 G.R No. 264029 JOENAR VARGAS AGRAVANTE, PETITIONER, VS. COMMISSION ON ELECTIONS, MUNICIPAL TRIAL COURT OF GOA, CAMARINES SUR, AND JOSEPH AMATA BLANCE, RESPONDENTS. August 8, 2023 DOCTRINE Time and again, this Court has held that procedural rules are tools designed to facilitate adjudication of cases, deliberately set in place to prevent arbitrariness in the administration of justice. Since the right to appeal is not a constitutional right but a mere statutory privilege, anyone who seeks to invoke such privilege must comply with the applicable rules; otherwise, the right to appeal is forfeited. While it has been held in previous cases that "[t]echnicalities and procedural niceties in election cases should not be made to stand in the way of the true will of the electorate," such pronouncement cannot be construed as a license for parties in election cases to disregard procedural rules altogether. This Court never intended to establish the precedent that the "true will of the electorate" may be used as an excuse for all kinds of procedural errors., no matter how numerous or serious they may be. FACTS OF THE CASE Petitioner and Joseph Amata Blance (private respondent) were candidates for the position of Punong Barangay of Matacla, Goa, Camarines Sur, in the May 14, 2018 Barangay and Sangguniang Kabataan Elections (BSKE). Private respondent garnered 786 votes, while petitioner got 789 votes, the latter winning by a margin of three votes. Thus, petitioner was proclaimed the duly elected Punong Barangay of Matacla on May 15, 2018. Not satisfied with the election result, private respondent filed a protest on May 23, 2018 before the Municipal Trial Court (MTC) of Goa, Camarines Sur. On May 30, 2018, petitioner filed an Answer with Counterclaim and with Affirmative Defenses which are Grounds for a Motion to Dismiss and with Counter-Protest. Private respondent subsequently filed his Answer to Counterclaim/Counter-Protest on June 6, 2018. On October 15, 2018, the MTC promulgated its Decision granting the protest, the dispositive portion of which reads: WHEREFORE, premises considered, the proclamation of Joenar V. Agravante as the winning candidate is hereby SET ASIDE

2022-2026 Case Digests and Doctrines Page 62 of 128 and Joseph A. Blance is hereby DECLARED as the elected Punong Barangay of Matacla, Goa, Camarines Sur in the May 14, 2018 BSKE. On July 2, 2019, the COMELEC Division issued an Order, the fallo According to the COMELEC Division, based on petitioner's brief, he furnished the same to private respondent through registered mail. However, petitioner failed to submit an affidavit of mailing, the registry receipt as proof of service, and a written explanation as to why service by mail was resorted to in accordance with Secs. 11 and 13, Rule 13 of the Rules of Court, in relation to Sec. 3, Rule 12 of the COMELEC Rules of Procedure, as amended. Thus, petitioner's brief was deemed not filed for failure to comply with the said mandatory requirements. Based on the foregoing, it is clear that the COMELEC Division and the COMELEC En Banc acted in full conformity with applicable laws, rules, and jurisprudence without any hint of whimsicality, arbitrariness, or capriciousness. Their strict adherence to the rules cannot be deemed grave abuse of discretion nor even mere abuse of discretion. In fact, it is the inverse that holds true; the manifest disregard of basic rules and procedures is precisely what constitutes grave abuse of discretion. ISSUES 1. Whether the COMELEC En banc committed grave abuse of discretion amounting to lack of jurisdiction in dismissing petitioner’s appeal due to the latter’s failure to perfect the appeal in accordance with law. 2. Whether petitioner is entitled to a TRO, status quo ante order, or a writ of preliminary injunction. RULING • The petition is DISMISSED. The July 2, 2019 Order of the Commission on Elections First Division and the September 20, 2022 Resolution of the Commission on Elections En Banc No. 167-2018-B are AFFIRMED • Petitioner’s urgent prayer for the issuance of a temporary restraining order and/or status quo ante order or preliminary injunction is accordingly DENIED. RATIO DECIDENDI

2022-2026 Case Digests and Doctrines Page 63 of 128 The Supreme Court held that the COMELEC did not commit grave abuse of discretion in dismissing Agravante's appeal. Agravante failed to comply with the mandatory requirements for filing and serving his appeal brief, specifically by not submitting the required proof of service and written explanation for service by registered mail. Although he later attempted to cure these defects through a motion for reconsideration, he failed to provide a sufficient justification for his initial noncompliance. The Court ruled that procedural rules ensure orderly and fair proceedings and cannot be ignored simply because a party later seeks leniency. Furthermore, the Municipal Trial Court correctly excluded ballots that were not formally offered in evidence, as the rules expressly prohibit courts from considering evidence not formally offered. Consequently, the dismissal of the appeal and the exclusion of the unoffered ballots were both proper.

2022-2026 Case Digests and Doctrines Page 64 of 128 G.R. NO. 260650 ROBERTO “PINPIN” T. UY, JR. Versus COMMISSION ON ELECTIONS August 08, 2023 DOCTRINE: The Court emphasized that nuisance candidacy cannot be presumed merely from similarities in surnames, nicknames, or perceived lack of popularity. COMELEC must establish through substantial evidence that the candidate's filing was intended to prevent a faithful determination of the electorate's will. In discussing the constitutional purpose of Section 69 of the Omnibus Election Code, the Court reiterated: "The importance of barring nuisance candidates from participating in the electoral exercise is the avoidance of confusion and frustration in the democratic process by preventing a faithful determination of the true will of the electorate." The Court likewise stressed that a candidate's political viability is not the test of a bona fide candidacy: "Membership in a political party is not a requirement to run for senator under the current electoral framework while non-membership does not prevent a faithful determination of the will of the electorate. Also, the candidate's degree of success is irrelevant to bona fide intention to run for public office. A candidate 'has no less a right to run when he faces prospects of defeat as when he expected to win.'" As regards COMELEC's suspension of proclamation, the Court held that COMELEC may suspend the proclamation of a winning candidate only in cases expressly authorized by law. The power to suspend proclamation under Sections 6 and 7 of R.A. No. 6646 does not extend to nuisance-candidate proceedings under Section 69 of the Omnibus Election Code. Moreover, a candidate whose proclamation is sought to be suspended must be afforded due process, especially when the suspension directly affects his right to be proclaimed as the candidate receiving the highest number of votes. FACTS OF THE CASE: On November 16, 2021, Romeo M. Jalosjos, Jr. filed a petition before the COMELEC to declare Frederico P. Jalosjos a nuisance candidate and cancel his COC for the

2022-2026 Case Digests and Doctrines Page 65 of 128 Representative of the First District of Zamboanga del Norte. Romeo alleged that Frederico had “no bona fide intention to run for public office,” was not known as “Kuya Jan,” had no prior political experience, and the nickname “Kuya Jan” was confusingly similar to Romeo’s nickname, “Kuya Jonjon.” In his defense, Frederico asserted that he had a genuine intention to seek office, was the official candidate of the National Unity Part (NUP), possessed government platforms, incurred campaign expenses, and enjoyed party support. He likewise argued that voter confusion was unlikely because the names appearing on the ballot were not identical. Thereafter, on April 19, 2022, the COMELEC Second Division declared Frederico a nuisance candidate, ruling that the nicknames “Kuya Jonjon” and “kuya Jan” were allegedly phonetically similar and the circumstances indicated a lack of bona fide intent to run. Accordingly, his COC was cancelled. Meanwhile, during the May 9, 2022 elections, Roberto “Pinpin” Uy, Jr. obtained 69, 591 votes while Romeo garnered 69, 109 votes and Frederico received 5, 424 votes. Despite Romeo leading the race, Romeo move to suspend his proclamation, claiming that Frederico’s votes should be credited to him. Subsequently, the COMELEC En Banc suspended Roberto’s proclamation and later denied Frederico’s Motion for Reconsideration. The COMELEC further ordered that Frederic’s votes be credited to Romeo pursuant to Dela Cruz v. COMELEC. As a result, Romeo was proclaimed the winning representative of the First District of Zamboanga del Norte. Aggrieved, Roberto challenged the suspension of his proclamation, while Frederico questioned his declaration as a nuisance candidate and the crediting of his votes to Romeo. Their petitions were consolidated before the Supreme Court. ISSUES 1. Whether the COMELEC En Banc committed grave abuse of discretion in: a) Suspending the proclamation of Roberto Uy, Jr. as the winning candidate for Representative of the First District of Zamboanga del Norte; b) Declaring Frederico Jalosjos a nuisance candidate and cancelling his Certificate of Candidacy; and c) Crediting the votes cast in favor of Frederico Jalosjos to Romeo Jalosjos, Jr. and proclaiming the latter as the winning candidate.

2022-2026 Case Digests and Doctrines Page 66 of 128 RULING YES. COMELEC gravely abused its discretion in: a) Suspending Roberto Uy’s proclamation. b) Declaring Frederico Jalosjos a nuisance candidate. c) Crediting Frederico’s votes to Romeo Jalosjos, Jr. RATIO DECIDENDI A. On the Suspension of Roberto Uy's Proclamation The Court held that COMELEC gravely abused its discretion in suspending Roberto's proclamation. While Sections 6 and 7 of Republic Act No. 6646 authorize the suspension of proclamation in disqualification cases and petitions under Section 78 of the Omnibus Election Code, the Court stressed that: "Yet, a similar power to suspend the proclamation of a winning candidate is not available in proceedings filed under Section 69 of the OEC or a petition to refuse to give due course to or cancel a CoC against an alleged nuisance candidate." The Court further emphasized that public policy dictates that candidates receiving the highest votes should be proclaimed without unnecessary delay and that the board of canvassers is merely a ministerial body whose duty is to ascertain and declare the apparent result of the voting. Moreover, the Court found that Roberto was denied due process. His proclamation was suspended in a proceeding where he was not a party, despite the fact that the order directly affected his right to be proclaimed. Thus, the Court ruled that COMELEC "gravely abused its power and violated the rules on basic fairness when it suspended the proclamation of Roberto without giving him the opportunity to be heard." B. On the Declaration of Frederico Jalosjos as a Nuisance Candidate The Court held that COMELEC gravely abused its discretion in declaring Frederico a nuisance candidate. It reiterated that under Section 69 of the Omnibus Election Code, nuisance candidates are those who file their certificates of candidacy to mock the

2022-2026 Case Digests and Doctrines Page 67 of 128 election process, cause confusion among voters, or clearly demonstrate the absence of a bona fide intention to run for office. As explained by the Court: "The common thread of the three instances is that nuisance candidates filed their CoCs not to aspire or seek public office but to prevent 'a faithful determination of the true will of the electorate.' Applying this standard, the Court found that Frederico's membership in the National Unity Party was "not trivial and weighs heavily against a finding of nuisance candidacy." His nomination by a registered political party, acceptance as its official candidate, governmental platforms, and party support all negated the conclusion that he lacked a bona fide intention to run. The Court likewise rejected COMELEC's reliance on Frederico's lack of political experience and alleged lack of support, emphasizing: "The candidate's degree of success is irrelevant to bona fide intention to run for public office. A candidate 'has no less a right to run when he faces prospects of defeat as when he expected to win.” As to voter confusion, the Court found only a distant possibility thereof because the ballot entries "Jalosjos, Kuya Jan (NUP)" and "Jalosjos, Jr. Romeo (NP)" were sufficiently distinguishable. The Court held that the COMELEC's conclusion that "Kuya Jan" and "Kuya Jonjon" would confuse voters was "a product of too much inference without adequate proof." C. On the Crediting of Frederico's Votes to Romeo Jalosjos, Jr. The Court held that the crediting of Frederico's votes to Romeo necessarily falls once the declaration of nuisance candidacy is set aside. Since Frederico was not a nuisance candidate, he remained a legitimate candidate and all votes cast in his favor remained valid. As categorically stated by the Court: "The Comelec committed grave abuse of discretion in canceling Frederico's CoC absent supporting substantial evidence that he is a nuisance candidate. Frederico is a legitimate candidate and the votes he received are all valid." Consequently, there was no legal basis for transferring Frederico's votes to Romeo. Since Roberto Uy, Jr. obtained the highest number of valid votes during the elections,

2022-2026 Case Digests and Doctrines Page 68 of 128 the Court ruled that Romeo's proclamation must be annulled and COMELEC must proclaim Roberto as the duly elected Representative of the First District of Zamboanga del Norte. Section 69 of the Omnibus Election Code: Sec. 69. Nuisance candidates. - The Commission may motu proprio or upon a verified petition of an interested party, refuse to give due course to or cancel a certificate of candidacy if it is shown that said certificate has been filed to put the election process in mockery or disrepute or to cause confusion among the voters by the similarity of the names of the registered candidates or by other circumstances or acts which clearly demonstrate that the candidate has no bona fide intention to run for the office for which the certificate of candidacy has been filed and thus prevent a faithful determination of the true will of the electorate. As per the Supreme Court, nuisance candidates are those who filed their COC’s: 1. To put the election process in mockery or disrepute. 2. To cause confusion among the voters by the similarity of the names of the registered candidates, or; 3. Under circumstances or acts which clearly demonstrate that the candidate has no bona fide intention to fun for the office for which the COC has been filed.

2022-2026 Case Digests and Doctrines Page 69 of 128 G.R. No. 258805 St. Anthony College of Roxas City, Inc vs. Commission on Elections October 10, 2023 DOCTRINE In Mecano v. Commission on Audit, the Court held: Implied repeal by irreconcilable inconsistency takes place when the two statutes cover the same subject matter; they are so clearly inconsistent and incompatible with each other that they cannot be reconciled or harmonized; and both cannot be given effect, that is, the one law cannot be enforced without nullifying the other. FACTS OF THE CASE St. Anthony College et al. are owners or co-owners of tarpaulins, posters, murals, and other materials expressing support and soliciting votes for former Vice President Maria Leonor Gerona Robredo (Robredo), who was a presidential candidate in the May 9, 2022 national and local elections. They allege that these privately-owned materials were displayed in their respective private properties but were "forcefully dismantled, removed, destroyed, defaced, and/or confiscated" by the COMELEC's regional or field election officers pursuant to the COMELEC's "Oplan Baklas." According to St. Anthony College et al., the COMELEC's "Oplan Baklas" involves the removal and confiscation of "oversized" tarpaulins, posters, and campaign materials, including those owned by private individuals and posted or installed within their premises, residences, or establishments, pursuant to COMELEC Resolution No. 10730. ISSUE RULING In fine, the COMELEC's implementation of "Oplan Baklas" as against St. Anthony et al., is unconstitutional as it exceeded the bounds of permissible regulation under Republic Act No. 9006 and COMELEC Resolution No. 10730.

2022-2026 Case Digests and Doctrines Page 70 of 128 RATIO DECIDENDI While the posters and tarpaulins subject of the dispute seek and promote the election of a candidate, they were not produced or displayed "by or on behalf of and in coordination with candidates and political parties." On the contrary, it is undisputed that they were the result of privately-funded and privately-run initiatives and were displayed willingly by their owners on their own private property. Thus, they are beyond the scope of Sections 3 and 9, Republic Act No. 9006. To apply the size restrictions under Republic Act No. 9006 to the political speech of private persons would be to unduly expand the COMELEC's mandate and ignore the law's repeated and express references to candidates and political parties only. ELEMENTS SECTION 6. Lawful Election Propaganda. – Election propaganda, whether on television or cable television, radio, newspaper, the internet or any other medium, is hereby allowed for all bona fide candidates seeking national and local elective positions, subject to the limitation on authorize expenses of candidates and parties, observation of truth in advertising, and to the supervision and regulation by the COMELEC. c. Cloth, paper or cardboard posters, whether framed or posted, with an area not exceeding two (2) feet by three (3) feet, except that, at the site and on the occasion of a public meeting or rally, or in announcing the holding of said meeting or rally, streamers not exceeding three (3) feet by eight (8) feet in size, shall be allowed: Provided, That said streamers may be displayed five (5) days before the date of the meeting or rally and shall be removed within twenty-four (24) hours after said meeting or rally;

2022-2026 Case Digests and Doctrines Page 71 of 128 2024 Case Digests

2022-2026 Case Digests and Doctrines Page 72 of 128 G.R. No. 261107 ANA LIZA ARRIOLA PERALTA, PETITIONER, VS. COMMISSION ON ELECTIONS, REPRESENTED BY THE CAMPAIGN FINANCE UNIT, RESPONDENT. January 30, 2024 DOCTRINE The constitutional right to the speedy disposition of cases applies to preliminary investigations conducted by the COMELEC. When there is inordinate and unjustified delay in resolving an election offense complaint, and such delay prejudices the respondent, the complaint may be dismissed for violating Article III, Section 16 of the 1987 Constitution. The Court applies the Cagang v. Sandiganbayan framework in determining whether the delay is unconstitutional. FACTS OF THE CASE Petitioner ran for the position of Mayor in the Municipality of San Marcelino, Zam bales, during the May 10, 2010, National and Local Elections (2010 NLE). At the time, there were 20,301 registered voters in the municipality. In a Letter to petitioner dated October 1, 2014, Atty. Ferdinand T. Rafanan (Atty. Rafanan), Head of the Campaign Finance Unit of the COMELEC, stated that petitioner spent the amount of PHP 285,500.00 during the 2010 NLE per the Statement of Contributions & Expenditures (SOCE) which she submitted to the COMELEC on June 7, 2010. Under Section 100 of the OEC, as amended by Section 13 of Republic Act No. 7166, the maximum allowable expenditure for petitioner was PHP 3.00 per registered voter or a total of PHP 60,903.00. Thus, as petitioner appeared to have exceeded the limit set by law, Atty. Rafanan directed her to submit her written explanation as to why no charges should be filed against her for the election offense of overspending under Section 262 in relation to the OEC, Section 100, as amended by Republic Act No. 7166 Section 13. In her letter-response dated March 2, 2015, petitioner attached the respective affidavits of her contributors., along with their corresponding explanations or clarifications on the declarations made in the Schedule of Contributions Received and Reports of Contributors.

2022-2026 Case Digests and Doctrines Page 73 of 128 Lance Stefan L. Flamiano. - the amount of his tarpaulin contributions was mistakenly written as PHP 30,000.00 instead of PHP 3,000.00 Petitioner further indicated in her letter that she underwent hip stress fracture surgery on December 10, 2014, after suffering serious injuries from a vehicular accident in Cancun, Mexico, on November 10, 2014. Thus, her mobility was very restricted and limited from such date. In addition, petitioner maintained that the distance between her and her contributors restricted her from easily conducting verification considering that she was based in Makati City, while almost all of her contributors were based in the Province of Zambales. She then requested that she be allowed to submit relevant documents as soon as they become available. In the motu proprio Complaint23 filed before its Law Department on May 9, 2015, the COMELEC, through its Campaign Finance Unit, sought the determination of probable cause against petitioner for violation of the OEC, Section 100 in relation to Section 262, as amended by Republic Act No. 7166 (election overspending). The petitioner denied the allegations hurled against her in that there is neither any factual nor legal basis to charge her for election overspending. Mor~over, · petitioner maintained that the dismissal of the complaint is warranted considering that the factual allegations therein were not sufficient to support a finding of probable cause that she committed the offense of overspending under the OEC. Her total expenditures was only PHP 51,500.00 and not PHP 285,500.00 as stated in the complaint. In its Resolution No. 18-065636 dated August 8, 2018, the COMELEC En Banc adopted the recommendation of its Law Department that found probable cause to charge petitioner for the offense of election overspending under the OEC. Thus: The Commission RESOLVED, as it hereby RESOLVES, to adopt the recommendation of the Law Department finding probable cause to hold respondent ANA LIZA A. PERALTA for trial and the filing of information for violation of Section 100 of B.P. Blg. 881, otherwise known as the Omnibus Election Code (OEC), as amended by R.A. No. 7166, in relation to Section 262 of the same Code. Petitioner sought a reconsideration,39 but the C0MELEC En Banc denied the motion in the C0MELEC Resolution No. 21-0472-5740 dated July 14,2021. Petitioner now comes before the Court imputing grave abuse of discretion on the part of the C0MELEC in that (1) there was inordinate delay in the conduct of the

2022-2026 Case Digests and Doctrines Page 74 of 128 preliminary investigation resulting in violation of petitioner's right to speedy disposition of cases; (2) it found probable cause against petitioner despite the absence of all the elements constituting the election offense; and (3) it found probable cause against petitioner notwithstanding the absence of substantial basis that she spent beyond the limits of the law. ISSUES Whether the COMELEC committed grave abuse of discretion amounting to lack or excess of jurisdiction when it issued the assailed Resolutions finding probable cause to charge petitioner with the election offense of overspending. RULING ACCORDINGLY, the petition is GRANTED. Resolution No. 18- 0656 dated August 8, 2018, and Resolution No. 21-0472-57 dated July 14, 2021, of the Commission on Elections En Banc in E.O. Case No. 15-954, are NULLIFIED for having been issued with grave abuse of discretion. The complaint against petitioner Ana Liza Arriola Peralta for alleged election overspending is DISMISSED. RATIO DECIDENDI The COMELEC violated Peralta's constitutional right to the speedy disposition of cases by allowing an unjustified twelve-year delay in resolving a simple election offense complaint without sufficient explanation, warranting the dismissal of the case.

2022-2026 Case Digests and Doctrines Page 75 of 128 G.R. No. 270564 SMARTMATIC TIM CORPORATION AND SMARTMATIC PHILIPPINES, INC., PETITIONERS, VS. COMMISSION ON ELECTIONS EN BANC, ELISEO MIJARES RIO, JR., AUGUSTO CADELIÑA LAGMAN, FRANKLIN FAYLOGA YSAAC, AND LEONARDO OLIVERA ODOÑO, RESPONDENTS. April 16, 2024 DOCTRINE 1. Due Process in Bidding: Under the Government Procurement Reform Act (GPRA), the procuring entity cannot preemptively disqualify a prospective bidder from participating and submitting documents without undergoing the mandatory, procedural evaluation of eligibility. 2. Grave Abuse of Discretion: Disqualifying a bidder based on grounds not yet established through standard procurement procedures or formal blacklisting proceedings constitutes grave abuse of discretion. FACTS OF TH CASE Private respondents Eliseo Mijares Rio, Jr., Augusto Cadeliña Lagman, Franklin Fayloga Ysaac, and Leonardo Olivera Odoño filed a petition with the Commission on Elections (COMELEC) to review and disqualify Smartmatic Philippines, Inc. as a prospective bidder for the 2025 Automated Election System (AES). They alleged that Smartmatic's failure to comply with minimum system capabilities led to serious irregularities in the 2022 NLE. The COMELEC debunked these allegations but still decided to disqualify and disallow Smartmatic from participating in any public bidding process for elections due to an ongoing investigation by the US government into violations of U.S. criminal laws, including the Foreign Corrupt Practices Act ISSUES: • Did the COMELEC act with grave abuse of discretion in disqualifying Smartmatic from participating in any public bidding process for elections prior to the submission of its bidding documents? • The application of the operative fact doctrine in ensuring the conduct of free and fair elections

2022-2026 Case Digests and Doctrines Page 76 of 128 RULING Yes, the Supreme Court ruled that the COMELEC committed grave abuse of discretion. The Court held that the COMELEC completely disregarded the provisions and procedures of the Government Procurement Reform Act (GPRA) and its Implementing Rules and Regulations (IRR). Under the GPRA, a prospective bidder must be allowed to submit its bidding documents, and the procuring entity can only determine eligibility after evaluating said documents. Furthermore, the Court found that the pending US investigation did not constitute a sufficient ground to disqualify the company at that stage of the procurement process. RATIO DECIDENDI The Commission on Elections (COMELEC) cannot invoke its broad constitutional mandate to enforce election laws as a license to bypass or rewrite the specific statutory procedures mandated by the Government Procurement Reform Act (R.A. 9184). The Supreme Court ruled that when COMELEC acts as a procuring entity purchasing election technology, it is strictly bound by the uniform, objective, and non- discretionary "pass/fail" criteria set by procurement law. Consequently, the Court held that COMELEC committed grave abuse of discretion when it unilaterally disqualified Smartmatic from the public bidding process prior to the actual submission of bids, especially since it relied on unproven foreign criminal allegations rather than the established domestic grounds for blacklisting or disqualification outlined in R.A. 9184.

2022-2026 Case Digests and Doctrines Page 77 of 128 G.R. No. 262975 Magkakasama Sa Sakahan vs. Commission on Elections and Soliman Villamin,Jr. May 21, 2024 DOCTRINE The Court recognizes COMELEC’s authority over intra-party disputes. However, such authority has its own limitations as well. COMELEC can not substitute its own judgment for the members of the Party if such judgment is solely based on their interpretation of the said Party’s Constitution and By-Laws. A Party and its members must be allowed to interpret their own Constitution and By-Laws and resolve disputes or determining its leadership. FACTS OF THE CASE On January 17, 2019, MAGSASAKA, became an organization duly accredited and registered by the COMELEC as a regional party in Region III. On May 9, 2022 when National and Local Election happened, two Manifestations of Intent to Participate were filed under the name of MAGSASAKA. The first was filed by Atty. Du as MAGSASAKA Secretary-General, and the second was filed by Soliman Villamin Jr. who claimed to be MAGSASAKA’s National Chairperson. Atty Du. and several members of the MAGSASAKA filed petitions to deny due course to Villamin’s MIP. They argued that Villamin misrepresented himself and no longer had the authority to represent MAGSASAKA as he had been removed as the political party’s National Chairperson due to his alleged involvement in misconduct. According to the members of MAGSASAKA and its records, Villamin and his group had been formally expelled and removed from the political party since June 26, 2021 when the new Council of Leaders was elected and a General Assembly happened on the said date. Villamin filed a petition regarding his removal from the political party, arguing that he was not properly notified of the meetings nor given the grace to defend himself, making his expulsion from the group invalid under MAGSASAKA’s Constitution and By-Laws. The COMELEC First Division ruled in Villamin’s favor, arguing that Villamin’s removal from the political party indeed violated its own rules regarding due process.

2022-2026 Case Digests and Doctrines Page 78 of 128 Hence, Villamin remained as the legitimate National Chairperson of the MAGSASAKA Party List and was authorized to file MIP. Members of MAGSASAKA elevated the case to the Supreme Court, filing for a Petition for Certiorari. They argued that the COMELEC gravely abused its discretion by involving itself with the party’s internal disputes and ruling in Villamin’s favor despite the valid rationale behind his expulsion. ISSUES Whether or not the COMELEC committed grave abuse of discretion in issuing COMELEC First Division Resolution dated November 25, 2021 and COMELEC En Banc Resolution dated September 9, 2022 in the consolidated cases of SPP No. 21-001 and SPP No. 21-003. RULING The petition made by the members of MAGSASAKA is GRANTED. • The Court ruled that COMELEC indeed committed grave abuse of discretion when its decision was focused on the procedural defects of Villamin’s expulsion from the group all while disregarding the substantive rationale behind his removal. RATIO DECIDENDI The Extent Of COMELEC’s Jurisdiction On Intra-Party Disputes The Court finds that the COMELEC gravely abused its discretion when it focused on purely procedural matters and disregarded the substantive issues raised by MAGSASAKA in the proceedings below, refused to acknowledge established party practice, and substituted its mandate for that of MAGSASAKA, thereby unlawfully instituting Villamin as its National Chairperson. In doing so, the COMELEC forced the members of the party to retain a leader they deemed unfit and to have committed misconduct as their National Chairperson, all because the COMELEC dwelled solely on procedural matters.

2022-2026 Case Digests and Doctrines Page 79 of 128 G.R. No. 258449 JUAN JUAN OLILA OLLESCA, PETITIONER, VS. COMMISSION ON ELECTIONS, RESPONDENT. July 30, 2024 DOCTRINE We reiterate this Court's rulings in Marquez (2019), De Alban, and Marquez (2022) that: (a) the COMELEC cannot conflate financial capacity requirement with the bona fide intention to run for public office; and (b) the imposition of having financial capacity to hit the campaign trail is a property qualification that is prohibited under the constitution and is likewise not a valid ground to characterize a candidate as a nuisance candidate. To emphasize, the pivotal criterion that characterizes a nuisance candidate lies in the absence of a bona fide intent to run for public office and it is incumbent upon the COMELEC to identify and to adduce supporting evidence of acts or circumstances that show a candidate's lack of bona fide intent to run for public office, with the objective of "prevent[ing] a faithful determination of the true will of the electorate."[89] This determination is governed by the statutes, and the concept is satisfactorily defined by the Omnibus Election Code. FACTS OF THE CASE The COMELEC Law Department filed, on its own initiative, a Petition[7] to declare Ollesca as a nuisance candidate and asked that the COMELEC deny due course to or cancel Ollesca's Certificate of Candidacy. It asserted that considering that Ollesca filed his Certificate of Candidacy to run for president, he should be publicly known by numerous voters.[8] However, he is running as an independent candidate and is "virtually unknown except possibly in the locality where he resides."[9] As such, he has no capability to launch a nationwide campaign to enable him to be known nationally within the campaign period and to persuade a substantial number of voters from different parts of the country.[10] Viewed in this light, he does not appear to have any bona fide intention to run and "put[s] the election process in mockery or disrepute. Ollesca asserted that the COMELEC Law Department's allegations are baseless conclusions of law,[14] being mere speculations[15] that lack factual basis to demonstrate Ollesca's lack of bona fide intent to run or any other circumstance or act intended to cause confusion among the voters.[16] He argued that the COMELEC's petition was

2022-2026 Case Digests and Doctrines Page 80 of 128 based on his alleged lack of financial capacity to wage a nationwide campaign, which effectively imposed a property qualification that is inconsistent with the Constitution[17] and lacked legal basis. ISSUES whether the Commission on Elections acted with grave abuse of discretion in declaring respondent Juan Juan Olila Ollesca as a nuisance candidate RULING This Court granted Marquez's petition and found that the COMELEC "committed grave abuse of discretion when it declared Marquez a nuisance candidate on the ground of lack of proof of his financial capacity to wage a nationwide campaign. RATIO DECIDENDI A candidate's financial capacity to sustain the rigors of waging a nationwide campaign does not necessarily equate to a bona fide intention to run for public office. The COMELEC's burden is thus to show a reasonable correlation between proof of a bona fide intention to run, on the one hand, and proof of financial capacity to wage a nationwide campaign on the other.

2022-2026 Case Digests and Doctrines Page 81 of 128 G.R. No. 264661 Clarylyn A. Legaspi, et al. vs. Commission on Elections July 30, 2024 DOCTRINE The constitutional right of suffrage does not include a right on the part of ordinary voters to compel a province-wide manual recount of election results based solely on suspicions, conjectures, or unverified allegations of fraud. Such right is neither found in statute nor jurisprudence. The Court likewise held that while the constitutional right to information on matters of public concern remains enforceable, parties must first comply with the applicable Freedom of Information (FOI) procedures established by the concerned government agency before seeking judicial intervention. Further, certiorari requires proof of grave abuse of discretion, while mandamus requires a clear legal right and a corresponding ministerial duty. Where no such right or duty exists, neither remedy will prosper. FACTS OF THE CASE Following the May 9, 2022 National and Local Elections, a group of voters from Pangasinan circulated and submitted to COMELEC a document entitled“Apela Para sa Mano-Manong Pagbilang Muli ng mga Boto sa Probinsya ng Pangasinan.” The document requested a province-wide manual recount of the ballots, alleging that widespread election fraud had occurred and asserting that the official results were inconsistent with the votes allegedly cast by the electorate. The COMELEC Law Department replied that the request did not satisfy the requirements of an election protest and informed the proponents that election contests may only be initiated by candidates who satisfy the requirements provided by law. Thereafter, Atty. Laudemer I. Fabia, acting as spokesperson of the affected voters, asked COMELEC to reconsider. He maintained that the appeal was not an election protest but a“people’s initiative” and an exercise of the people's constitutional rights to suffrage and information. He requested a manual recount, examination of ballots, audit of SD cards, and the presentation of evidence allegedly showing irregularities in the conduct of the elections. The COMELEC again replied and explained that it had no jurisdiction over the request in the form presented and directed petitioners to the applicable procedures governing initiatives and other petitions.

2022-2026 Case Digests and Doctrines Page 82 of 128 Claiming that COMELEC effectively denied their constitutional rights to suffrage, information, and redress of grievances, petitioners filed a Petition for Certiorari and Mandamus before the Supreme Court. ISSUES Whether the COMELEC committed grave abuse of discretion amounting to lack or excess of jurisdiction in not granting petitioners’ request for a province-wide manual recount of the votes cast in Pangasinan during the May 9, 2022 National and Local Elections. RULING No. The COMELEC did not commit grave abuse of discretion amounting to lack or excess of jurisdiction. The Petition for Certiorari and Mandamus was dismissed. RATIO DECIDENDI The Court held that petitioners failed to establish any legal basis for compelling COMELEC to conduct a province-wide manual recount of all ballots cast in Pangasinan. First, the Court ruled that the petition itself suffered from fundamental defects. Petitioners claimed personal knowledge of election anomalies, yet their allegations were based largely on social media posts, internet commentaries, news reports, opinions of unnamed experts, and unverified materials rather than on personal knowledge or authenticated documents as required under the Rules of Court. Consequently, the alleged factual basis of the petition consisted mainly of speculation, hearsay, and personal suspicions. Second, the Court found that petitioners lacked sufficient legal standing. They did not demonstrate any concrete injury resulting from COMELEC’s actions. Petitioners admittedly were able to vote during the elections and were not prevented from exercising their right of suffrage. Their alleged injury consisted only of doubts regarding the integrity of the electoral process, which the Court characterized as speculative and insufficient to constitute a legally cognizable injury. Third, the Court held that the right of suffrage does not carry with it a corresponding right to demand a manual recount of an entire province’s election results based merely on suspicions of irregularity. Such a right has no basis in the Constitution, statutes, or jurisprudence. To recognize such a right would amount to judicial legislation.

2022-2026 Case Digests and Doctrines Page 83 of 128 The Court rejected petitioners’ reliance on Loong v. COMELEC. In that case, manual counting was authorized because the vote-counting machines failed to correctly read the ballots, thereby preventing accurate vote tabulation. By contrast, petitioners in the present case did not allege any comparable failure of the vote-counting machines, failure of transmission, or failure of elections that would justify extraordinary intervention by COMELEC. Fourth, the Court ruled that petitioners' claim based on the constitutional right to information was likewise unavailing. While election-related records may indeed constitute matters of public concern, petitioners never filed a proper request under COMELEC Resolution No. 10685, which provides COMELEC's Freedom of Information procedures. Without first availing themselves of those procedures and exhausting available administrative remedies, petitioners could not validly claim that their right to information had been denied. Finally, neither certiorari nor mandamus could prosper. Certiorari failed because no grave abuse of discretion was shown. COMELEC merely attempted to respond to petitioners' confusing and legally unsupported requests. Mandamus likewise failed because petitioners could point to no clear legal right to a province-wide manual recount, and COMELEC had no ministerial duty under law to conduct such recount. Accordingly, the Court held that there was no actual denial of any constitutional right and no grave abuse of discretion on the part of COMELEC.

2022-2026 Case Digests and Doctrines Page 84 of 128 G.R. No. 273136 Eliseo Mijares Rio, Jr., Augusto Cadelina Lagman, and Franklin Fayloga Ysaac versus Commission on Elections En Banc. August 20, 2024 DOCTRINE The writ of mandamus does not lie to compel COMELEC to exercise its discretion in a particular manner. However, COMELEC may be compelled to perform a duty that is ministerial in nature, such as resolving motions within the period prescribed by its own rules. As stated by the Court: "The Commission on Elections (COMELEC) may not be compelled by mandamus to exercise its discretion in a certain way, i.e., to grant or deny the opening and recounting of ballot boxes. However, it has a clear legal duty to expeditiously resolve motions pending before it, following its own rules of procedure." The Court further reiterated: "Mandamus may only be resorted to in order to compel respondent tribunal, corporation, board, officer or person to take action, but it cannot be used to direct the manner or the particular way discretion is to be exercised, or to compel the retraction or reversal of an action already taken in the exercise of judgment or discretion." FACTS OF THE CASE The controversy arose from petitions filed by Eliseo Mijares Rio, Jr., Augusto Cadelina Lagman, and Franklin Fayloga Ysaac before the COMELEC En Banc questioning alleged irregularities in the 2022 National and Local Elections and seeking, among others, the review of Smartmatic's qualifications to participate in future election procurements. Subsequently, on November 29, 2023, the COMELEC En Banc granted the petition, disqualified Smartmatic from participating in future election bidding processes, and further resolved that it"may, upon Petitioner's instance, order the conduct of the recount of ballots in areas in every region in the country, the procedure and extent of which to be determined."

2022-2026 Case Digests and Doctrines Page 85 of 128 Thereafter, on January 19, 2024, petitioners filed a Motion seeking the opening and recount of at least thirty sealed ballot boxes in Sto. Tomas, Batangas pursuant to the November 29, 2023 Resolution. When no action was taken, they filed a Reiterative Motion on February 12, 2024. Claiming that COMELEC had failed to act on their motions, petitioners filed before the Supreme Court a Petition for Mandamus to compel COMELEC to implement its November 29, 2023 Resolution by conducting the requested recount. While the case was pending, COMELEC issued an Order dated July 3, 2024 denying the Motion and Reiterative Motion. Petitioners subsequently sought to convert their action into a petition for certiorari assailing the July 3, 2024 Order. ISSUES Whether the COMELEC En Banc committed grave abuse of discretion and may be compelled through mandamus to implement its November 29, 2023 Resolution by ordering the opening and recount of ballots. a) Whether the opening and recount of ballots constituted a ministerial duty that may be compelled by mandamus. b) Whether COMELEC failed to perform a legal duty when it did not immediately resolve petitioners' Motion and Reiterative Motion. c) Whether COMELEC gravely abused its discretion in issuing the July 3, 2024 Order denying petitioners' motions. RULING A. Whether the opening and recount of ballots constituted a ministerial duty that may be compelled by mandamus. No. B. Whether COMELEC failed to perform a legal duty when it did not immediately resolve petitioners' Motion and Reiterative Motion. Yes, COMELEC delayed the resolution of the motions beyond the period prescribed by its own rules, but such delay did not justify the issuance of mandamus directing the recount.

2022-2026 Case Digests and Doctrines Page 86 of 128 C. Whether COMELEC gravely abused its discretion in issuing the July 3, 2024 Order denying petitioners' motions. No. RATIO DECIDENDI A. On Whether the Recount Could Be Compelled by Mandamus The Court held that petitioners failed to establish a clear legal right to the recount and a corresponding ministerial duty on the part of COMELEC. The Court observed that petitioners failed to identify any law specifically requiring the conduct of a recount of the physical ballots in the 2022 National and Local Elections or prescribing the manner of such recount so that no discretion would be left to COMELEC. More importantly, the November 29, 2023 Resolution itself merely provided that COMELEC: "may, upon Petitioner's instance, order the conduct of the recount of ballots in areas in every region in the country" and that the: "procedure and extent" of the recount were still "to be determined. Thus, the Court concluded that the recount required the exercise of COMELEC's judgment and discretion. Since mandamus applies only to the performance of ministerial duties, petitioners failed to establish any clear, complete, and specific legal right enforceable by mandamus. B. On COMELEC's Delay in Resolving the Motions Although the Court denied the writ, it agreed that COMELEC failed to act within the period prescribed by its own rules. The Court noted that Rule 18 of the COMELEC Rules of Procedure requires that matters submitted to the COMELEC En Banc be resolved within thirty (30) days from submission. Yet petitioners' motions remained unresolved for 166 and 142 days, respectively. The Court expressly shared the view that COMELEC was guilty of official inaction because it resolved the motions long after the period fixed by its own procedural rules. Accordingly, the Court reminded COMELEC that:

2022-2026 Case Digests and Doctrines Page 87 of 128 "it has a clear legal duty to expeditiously resolve motions pending before it, following the COMELEC rules of procedure" and that it may be compelled by mandamus to act when it unlawfully neglects such duty. Nevertheless, mandamus may only compel COMELEC to resolve pending motions, not to decide them in a particular way. C. On the July 3, 2024 COMELEC Order The Court found no grave abuse of discretion in COMELEC's issuance of the July 3, 2024 Order. The COMELEC concluded that petitioners themselves had abandoned the reliefs sought in their Motion and Reiterative Motion and instead pursued a declaration of failure of elections based on their assertion that the transmitted results did not reflect the true will of the electorate. The Court held that COMELEC's determination was not attended by capriciousness, arbitrariness, or grave abuse of discretion. Since the requested recount remained a matter committed to COMELEC's sound discretion, mandamus could not be used to compel COMELEC to grant the recount, nor could certiorari prosper absent grave abuse of discretion. The Court reiterated: "Mandamus may only be resorted to in order to compel respondent tribunal, corporation, board, officer or person to take action, but it cannot be used to direct the manner or the particular way discretion is to be exercised."

2022-2026 Case Digests and Doctrines Page 88 of 128 G.R. No. 264071 Ben D. Ladilad vs. Commission on Elections and Mary Grace Bandoy August 13, 2024 DOCTRINE Speedy Disposition The right to speedy disposition of cases or the right to speedy trial must be timely raised. The respondent or the accused must file the appropriate motion upon the lapse of the statutory or procedural periods. Four Factors to Determine a Person’s Right to a Speedy Disposition In Baya v. Sandiganbayan, Baya laid out four factors comprising the balancing act by which courts determine whether or not a person’s right to a speedy disposition of cases is violated. The four factors are: 1) the length of the delay; 2) the reason for the delay; 3) the respondent’s assertion of the right, and 4) prejudice to the respondent. These four need to be considered together, and not in isolation. The interplay of these factors determine whether the delay was inordinate or not. FACTS OF THE CASE On June 27, 2013, Mary Grace Bandoy, a graft researcher, filed a Complaint against Ben Ladilad and Luciana M. Villanueva for violating the Section 261, paragraphs (g) and (h) of the Omnibus Election Code in relation to COMELEC Resolution No. 9581. Ladilad was the President of Benguet State University, and Villanueva was the Vice President for Research and Extension (OVPRE) also of BSU. Their respective position and capacities that comes along entangled them with the allegation that they have caused the illegal detail and transfer within the BSU offices of Gretchen Gaye Ablaza and Frances Noelle Escalera, both BSU employees during the 2013 election period without prior COMELEC approval. Ablaza was transferred from the Graduate School Office (GSO) to the OVPRE on March 25, 2013 through a letter that was penned by Villanueva, and was approved by Ladilad. Escalera, on the other hand, was transferred from the Internal Auditing Service (IAS) to the Human Resource Management Office (HRMO). The Office of the Regional Election Director-Cordillera Administrative Region or ORED-CAR recommended COMELEC to file a case for violation of the OEC, Sec. 261

2022-2026 Case Digests and Doctrines Page 89 of 128 (h), against Ben D. Ladilad in relation to COMELEC Resolution No. 9581, based on the finding that while Ablaza was not technically transferred, Escalera’s detail still fell within the prohibition. The case was elevated to COMELEC En Banc, and the Commission En Banc considered Ablaza and Escalera’s personnel movements as transfers prohibited during the 2013 election period. Thus, the Comelec En Banc released a Resolution dated November 4, 2014 that directed the Law Department of the said Commission to file a criminal charge against respondents Ben D. Ladilad and Luciana M. Villanueva for violation of Section 261, paragraph (h) of the Omnibus Election code as implemented by COMELEC Resolution No. 9581. Ladilad and Villanueva moved for a reconsideration of the COMELEC Resolution dated November 4, 2014, which the COMELEC En Banc denied in its Resolution dated September 27, 2022. It has taken COMELEC eight years to resolve Ladilad’s motion for reconsideration, which made Ladilad file a Petition for Certiorari under Rule 64 in relation Rule 65 before the Supreme Court with an argument that the COMELEC committed grave abuse of discretion due to its inordinate delay in resolving his case. ISSUE Did the COMELEC commit grave abuse of discretion amounting to a lack or in excess of jurisdiction when it found probable cause against Ladilad for violation of the OEC, Sec. 261(h), in relation to COMELEC Resolution No. 9581? RULING The petition is GRANTED. The Court ruled in favor of the petitioner, citing that the COMELEC indeed committed grave abuse of discretion due to the fact it unjustifiably delayed the resolution of Ladilad’s motion for reconsideration, leading to the violation of Ladilad’s right to speedy disposition of cases. RATIO DECIDENDI The Court ruled that it was incorrect for the COMELEC to say that Ladilad had waived his right to a speedy disposition of cases, given that Ladidad moved for the early

2022-2026 Case Digests and Doctrines Page 90 of 128 resolution of his case on September 14, 2014, and it is only COMELEC who have failed to decide his appeal within 30 days, which also exhibits that COMELEC failed to follow the Rules of Procedure. The Court further stated that COMELEC in this instance, as the governing agency, is tasked to promptly resolve such cases, which did not happen in Ladilad’s case and was not even adduced for justifiable reason.

2022-2026 Case Digests and Doctrines Page 91 of 128 G .R. No. 265847 MA. ZARAH ROSE DE GUZMAN-LARA vs. COMMISSION ON ELECTIONS and MANUEL N. MAMBA, August 6, 2024 DOCTRINE The Court emphasized that procedural rules are subservient to substantive law and are intended to effectuate substantive rights. It relied on prior decisions that relaxed procedural rules in election matters when necessary to prevent grave injustice, including Uy v. Commission on Elections. The Court concluded that the COMELEC should have exercised liberality in the application of its own electronic-filing rule given the public interest in election disputes, the brief temporal gap between the e-mail filing and proclamation, the Second Division's on-record findings, and the technological realities of electronic transmission. FACTS OF THE CASE During the May 2022 National and Local Elections (NLE), Lara and Mamba were candidates for the position of Governor of the Province of Cagayan. Mamba was then the incumbent Governor of the said province, having been elected as such during the May 2019 NLE. Lara filed a Petition5 dated May 10, 2022, seeking the disqualification of Mamba as a candidate for the position of Governor of the Province of Cagayan in the May 2022 NLE on the grounds of massive vote-buying activities and unlawful disbursement of public funds, in blatant violations of Section 686 of the Omnibus Election Code (OEC). 7 In the same Petition, Lara likewise prayed that the COMELEC order and direct the Board of Canvassers to suspend and hold in abeyance the proclamation of Mamba as winner, should the latter receive the highest number of votes in the elections. 8 Specifically, Lara averred that Mamba used the funds of the provincial government of Cagayan to distribute cash assistance "ayuda" to voters under the following programs: (1) "No Barangay Left Behind;" (2) "No Town Left Behind;" (3) Oplan Tulong sa Barangay;" (4) and "Krusada Kontra Korapsyon." Lara likewise contended that the disbursements were done during the campaign period of March 25 to May 8, 2022.9

2022-2026 Case Digests and Doctrines Page 92 of 128 Mamba moved for partial reconsideration. On March 6, 2023 the COMELEC En Banc reversed and dismissed Lara’s petition for lack of jurisdiction, holding that under COMELEC Resolution No. 10673, Section 5 pleadings filed by e-mail after 5:00 P.M. are deemed filed at 8:00 A.M. of the next working day; applying that rule, the En Banc deemed Lara’s May 10, 2022 e-mail as filed on May 11, 2022 at 8:00 A.M., which was after Mamba’s proclamation, and therefore outside COMELEC’s jurisdiction. The Supreme Court holds that a petition for disqualification of a candidate based on Section 68 of the OEC may be filed during the period beginning the whole day after the last day of filing of certificate of candidacy until the end of the day of the date of proclamation, even after the exact time of the proclamation of the winning candidate. ISSUE • Did the COMELEC En Banc commit grave abuse of discretion amounting to lack or excess of jurisdiction in dismissing the Petition for Disqualification as filed out of time? • Did the COMELEC En Banc commit grave abuse of discretion in failing to affirm the COMELEC Second Division’s December 14, 2022 Resolution of disqualification. RULING The Supreme Court held that the COMELEC En Banc gravely abused its discretion in dismissing the petition that was filed out of time. The Court declared that a petition for disqualification under Section 68 may be filed during the period beginning the whole day after the last day for filing certificates of candidacy until the end of the day of the date of proclamation, even if filed after the exact moment of proclamation so long as it is within that calendar day. The Court annulled and set aside the March 6, 2023 COMELEC En Banc Resolution and remanded the case to the COMELEC En Banc for proper disposition of Lara's Petition for Disqualification. The Court directed that its holding be applied prospectively and not to prejudice parties who relied in good faith on the former interpretation. RATIO DECIDENDI In G.R. No. 265847, the Supreme Court ruled that a disqualification petition filed on the same calendar day as a candidate's proclamation is timely, even if submitted after

2022-2026 Case Digests and Doctrines Page 93 of 128 5:00 P.M. or following the specific time of proclamation. The Court established that "date" under the Omnibus Election Code refers to the full 24-hour calendar day and that administrative cut-off times cannot override substantive legal rights regarding filing periods.

2022-2026 Case Digests and Doctrines Page 94 of 128 G.R. No. 268546 AN WARAY Party-List, represented by Florencio Gabriel “Bem” Noel and Victoria Isabel Noel versus Commission on Elections, Danilo T. Pomias, Jr., and Jude A. Acidre August 6, 2024 DOCTRINE The Court held that the power to register and cancel the registration of party-list organizations belongs exclusively to the COMELEC under the Constitution and Republic Act No. 7941. Thus: "Jurisdiction over cancellation of party-list registrations is categorically conferred by Section 6 of Republic Act No. 7941 on COMELEC." The Court further emphasized that: "Although it is the party-list organization that is voted for in the elections, it is not the organization that sits as and becomes a member of the House of Representatives, but it is the party-list nominee/representative who sits as a member of the House of Representatives." Accordingly, while the HRET has jurisdiction over contests involving the election, returns, and qualifications of party-list nominees who become Members of the House of Representatives, the cancellation of a party-list registration remains within the exclusive jurisdiction of the COMELEC FACTS OF THE CASE In the 2013 National and Local Elections, AN WARAY Party-List obtained 541,205 votes and initially secured two seats in the House of Representatives pursuant to NBOC Resolution No. 0008-13. Following the resignation of its second nominee, Jude A. Acidre, Victoria Isabel Noel became the second nominee and subsequently took her oath of office as a member of the House of Representatives. Thereafter, in Abang Lingkod Party-List v. COMELEC, the Supreme Court ordered the proclamation of another party-list organization, prompting COMELEC to issue NBOC Resolution No. 13-030 (PL)/0004-14. Applying the BANAT formula, COMELEC finally determined that AN WARAY was entitled to only one seat in the House of Representatives.

2022-2026 Case Digests and Doctrines Page 95 of 128 Despite this, Victoria continued to occupy the second seat until the expiration of her term. Thus, on May 10, 2019, Danilo T. Pomias, Jr. and Jude A. Acidre filed a petition before COMELEC seeking the cancellation of AN WARAY's registration under Section 6(5) of Republic Act No. 7941, alleging that the party-list knowingly allowed Victoria to assume and occupy a second seat despite the absence of a Certificate of Proclamation and despite COMELEC's final determination that AN WARAY was entitled to only one seat. The COMELEC Second Division granted the petition and cancelled AN WARAY's registration. The COMELEC En Banc affirmed. Aggrieved, AN WARAY and Victoria Noel elevated the matter to the Supreme Court through a petition for certiorari, alleging, among others, that COMELEC lacked jurisdiction, violated their right to speedy disposition of cases, and acted with grave abuse of discretion. ISSUE Whether the COMELEC En Banc committed grave abuse of discretion amounting to lack or excess of jurisdiction in cancelling the registration of AN WARAY Party-List. RULING No. The COMELEC En Banc did not commit grave abuse of discretion in cancelling the registration of AN WARAY Party-List. RATIO DECIDENDI The Court first ruled that the COMELEC properly exercised jurisdiction over the petition. The case involved the cancellation of a party-list registration, a matter expressly placed by the Constitution and Republic Act No. 7941 under COMELEC's authority. While the HRET has jurisdiction over contests involving the election, returns, and qualifications of Members of the House of Representatives, the respondent in the cancellation case was the party-list organization itself and not a sitting Member of the House. Thus, the controversy did not fall within the HRET's jurisdiction. The Court explained that: "The HRET does not have jurisdiction over petitions to cancel the registration of party-lists, including those whose nominees are incumbent Members of the HoR."

2022-2026 Case Digests and Doctrines Page 96 of 128 On the merits, the Court found that COMELEC correctly concluded that AN WARAY violated election laws. Although the Court disagreed with COMELEC's finding that AN WARAY violated Section 13 of Republic Act No. 7941 regarding the proclamation of party-list representatives, it nevertheless found another sufficient ground for cancellation under Section 6(5) of the same law. The Court observed that NBOC Resolution No. 13-030 (PL)/0004-14, issued after the Court's ruling in Abang Lingkod, clearly and unequivocally declared that AN WARAY was entitled to only one seat in the House of Representatives. Despite notice of this Resolution, AN WARAY continued to occupy a second seat through Victoria Noel until the end of her term. The Court stressed: "Despite notice of such resolution indicating that it secured only one seat in the HoR after the 2013 NLE, An Waray continued to occupy a second seat through Victoria until the end of her term." The Court further noted that AN WARAY itself requested from COMELEC a Certificate of Proclamation in favor of Victoria, thereby demonstrating its awareness that such proclamation was necessary before she could validly assume office. Yet, despite the absence of the required Certificate of Proclamation, Victoria still took her oath and discharged the functions of a representative. Consequently, the Court held that AN WARAY knowingly and deliberately continued to occupy a seat to which it was no longer entitled, constituting a violation of election laws and regulations sufficient to justify cancellation of registration under Section 6(5) of Republic Act No. 7941. The Court likewise rejected AN WARAY's arguments based on speedy disposition of cases and prescription. It held that the delay in COMELEC proceedings did not violate the constitutional right to speedy disposition of cases because AN WARAY failed to timely invoke the right and failed to show actual prejudice arising from the delay. Moreover, a petition to cancel a party-list registration is not an election offense subject to the five-year prescriptive period under Section 267 of the Omnibus Election Code. Accordingly, COMELEC acted within its jurisdiction, on the basis of substantial evidence, and without capricious or arbitrary exercise of power. Therefore, no grave abuse of discretion could be attributed to the Commission.

2022-2026 Case Digests and Doctrines Page 97 of 128 G.R.No. 261123 Duty to Energize The Republic Through the Enlightenment of the Youth [Duterte Youth] Party-List vs. Commission on Elections August 20, 2024 DOCTRINE The Court held that rules and regulations governing the substitution of party-list nominees remain mandatory even after elections because they directly affect the electorate's constitutional right to information and its ability to make an informed choice. Post-election substitution cannot be used to circumvent statutory and regulatory restrictions governing party-list nominees. The Court emphasized: "Nominee substitution being a matter of substance, rules and regulations governing the same do not lose their mandatory character even after the elections." The case likewise clarifies that the COMELEC acts in an administrative capacity, not a quasi-judicial one, when approving substitutions of party-list nominees. FACTS OF THE CASE P3PWD Party-List participated in the 2022 National and Local Elections and initially submitted five nominees to the COMELEC. Prior to the elections, it withdrew and substituted four of its original nominees, which substitution was approved by the COMELEC. In the May 9, 2022 elections, P3PWD obtained sufficient votes to secure one seat in the House of Representatives. Its first nominee, Grace S. Yeneza, was proclaimed and later took her oath of office. Subsequently, all five nominees of P3PWD, including Yeneza, resigned. On June 14, 2022, P3PWD submitted a completely new list of nominees headed by former COMELEC Commissioner Ma. Rowena Amelia V. Guanzon. On June 15, 2022, the COMELEC En Banc approved the withdrawal of the previous nominees and gave due course to the new nominees, subject to compliance with publication requirements. Later, Guanzon was proclaimed as the representative of P3PWD. The Duterte Youth Party-List, represented by the Cardemas, filed a petition before the Supreme Court questioning the approval of the substitution, arguing that it violated COMELEC rules and the electorate's right to information because the substitution

2022-2026 Case Digests and Doctrines Page 98 of 128 occurred after the elections and beyond the deadlines established by COMELEC regulations. The Court issued a Temporary Restraining Order enjoining implementation of the COMELEC approval. ISSUE Whether the COMELEC committed grave abuse of discretion amounting to lack or excess of jurisdiction in approving the post-election substitution of all nominees of P3PWD Party-List. RULING Yes. The COMELEC committed grave abuse of discretion in approving the post- election substitution of P3PWD's nominees. RATIO DECIDENDI The Court held that although the Party-List System Act allows withdrawal and substitution of nominees in specific instances, the statute must be read together with the COMELEC regulations implementing it. COMELEC Resolution No. 9366, as amended by Resolution No. 10690, expressly established deadlines for substitutions caused by withdrawal and limited substitutions beyond the deadline only in cases of death or incapacity. These regulations remained mandatory even after the elections. The Court rejected the theory that election rules become merely directory after elections. While that principle may apply to matters of form, it cannot apply where the right of the electorate to know the identity of party-list nominees is affected. The identity of nominees is a matter of substance because voters are entitled to know who may eventually represent them in Congress before casting their votes. Citing Lokin v. COMELEC, COCOFED v. COMELEC, and BA-RA 7941 v. COMELEC, the Court reiterated that publication of party-list nominees exists to protect the electorate's constitutional right to information and to ensure informed voting. Allowing wholesale substitution after the elections would defeat this constitutional objective because voters would never have had the opportunity to scrutinize the actual individuals who would eventually occupy congressional seats. The Court further ruled that Section 16 of the Party-List System Act, which allows the submission of additional nominees upon exhaustion of the nominee list, was

2022-2026 Case Digests and Doctrines Page 99 of 128 inapplicable. Section 16 contemplates vacancies occurring during the term of a party- list representative after assumption of office. At the time of the resignations, P3PWD's seat had not yet legally commenced. Hence, no vacancy existed that could justify reliance on Section 16. The Court also found that the COMELEC acted arbitrarily in approving the substitution. It approved the new nominees with unusual speed, disregarded concerns regarding publication requirements, disregarded its own deadlines, and departed from its established procedures. A memorandum from one COMELEC commissioner even warned against such irregular action. These circumstances, taken together, demonstrated capricious and whimsical exercise of judgment amounting to grave abuse of discretion. Consequently, the approval of the substitutions had no legal effect and had to be nullified.

2022-2026 Case Digests and Doctrines Page 100 of 128 G.R. No. 242255 PROVINCE OF SULU, DULY REPRESENTED BY ITS GOVERNOR, ABDUSAKUR A. TAN II, versus PHILIPPINE ASSOCIATION OF ISLAMIC ACCOUNTANTS [PAIA], INC., REPRESENTED BY ITS PRESIDENT, AMANODING D. ESMAIL, CPA, ET AL.; GOVERNOR ESMAEL G. MANGUDADATU, ET AL.; AND ALGAMAR A. LATIPH, ET AL.; PETITIONERS-IN-INTERVENTION; VS. HON. SALVADOR C. MEDIALDEA, IN HIS CAPACITY AS EXECUTIVE SECRETARY; HONORABLE EDUARDO M. AÑO, IN HIS CAPACITY AS OFFICER-IN-CHARGE OF THE DEPARTMENT OF INTERIOR AND LOCAL GOVERNMENT; THE HONORABLE SENATE OF THE PHILIPPINES; THE HONORABLE HOUSE OF REPRESENTATIVES; THE HONORABLE COMMISSION ON ELECTIONS; HONORABLE JESUS G. DUREZA, IN HIS CAPACITY AS SECRETARY OF THE OFFICE OF THE PRESIDENTIAL ADVISER ON THE PEACE PROCESS; BANGSAMORO TRANSITION COMMISSION; AND MORO ISLAMIC LIBERATION FRONT, RESPONDENTS. G.R. No. 243246 PHILIPPINE CONSTITUTION ASSOCIATION [PHILCONSA], PETITIONER, VS. SENATE OF THE PHILIPPINES, REPRESENTED BY SENATE PRESIDENT HONORABLE VICENTE SOTTO; HOUSE OF REPRESENTATIVES, REPRESENTED BY SPEAKER HONORABLE GLORIA MACAPAGAL ARROYO; AND OFFICE OF THE PRESIDENT, REPRESENTED BY EXECUTIVE SECRETARY HONORABLE SALVADOR MEDIALDEA, RESPONDENTS. G.R. No. 243693 CONG. ABDULLAH D. DIMAPORO AND CONG. MOHAMAD KHALID Q. DIMAPORO, PETITIONERS, VS. COMMISSION ON ELECTIONS [COMELEC], AS REPRESENTED BY HON. CHAIRPERSON SHERIFF ABAS, RESPONDENT. September 9, 2024

2022-2026 Case Digests and Doctrines Page 101 of 128 DOCTRINE Under Article X, Section 18 of the 1987 Constitution, inclusion in an autonomous region requires the affirmative vote of the individual province, city, or geographic area concerned. A province that votes against inclusion cannot be compelled to become part of an autonomous region based on the collective vote of other areas. The constitutional requirement of plebiscitary consent protects the right of local communities to determine their political status and ensures that autonomy is established through genuine consent of the people. Furthermore, when only a specific provision of a law is found unconstitutional, the remainder of the statute may continue to operate if it can stand independently and still fulfill the legislative purpose. This applies through the doctrine of separability. FACTS OF THE CASE On July 27, 2018, President Rodrigo Roa Duterte signed into law Republic Act No. 11054, otherwise known as the Bangsamoro Organic Law (BOL). The law abolished the Autonomous Region in Muslim Mindanao (ARMM) and established the Bangsamoro Autonomous Region in Muslim Mindanao (BARMM), providing for its governmental structure, powers, and territorial jurisdiction. It also required the conduct of a plebiscite to determine the ratification of the law and the territorial composition of the new autonomous region. Prior to the plebiscite, the Province of Sulu, represented by Governor Abdusakur A. Tan II, filed a petition for Certiorari and Prohibition before the Supreme Court. The Province challenged the constitutionality of several provisions of the Bangsamoro Organic Law, arguing that the law violated the 1987 Constitution by abolishing the ARMM, creating a parliamentary form of regional government, granting powers beyond those authorized by the Constitution, and providing for the inclusion of Sulu in the BARMM despite the constitutional requirement that only provinces, cities, and geographic areas voting favorably in a plebiscite may be included in an autonomous region. Despite the pending petitions, the Commission on Elections proceeded with the Bangsamoro plebiscite on January 21 and February 6, 2019. While the Bangsamoro Organic Law was ratified by the required majority vote in the areas covered by the plebiscite, the voters of the Province of Sulu rejected the law, with a majority voting against its ratification. Nevertheless, Sulu remained included in the BARMM because

2022-2026 Case Digests and Doctrines Page 102 of 128 the former ARMM was treated as a single territorial unit for purposes of determining the overall result of the plebiscite. The petition was later consolidated with other cases questioning the constitutionality of the Bangsamoro Organic Law. Among the issues presented before the Supreme Court was whether the inclusion of Sulu in the BARMM, despite its rejection of the Bangsamoro Organic Law in the plebiscite, violated Article X, Section 18 of the 1987 Constitution, which provides that only the provinces, cities, and geographic areas voting favorably in a plebiscite shall be included in the autonomous region. ISSUES • Whether the inclusion of the Province of Sulu in the Bangsamoro Autonomous Region in Muslim Mindanao (BARMM), despite its rejection of the Bangsamoro Organic Law (BOL) during the plebiscite, violated Article X, Section 18 of the 1987 Constitution. • Whether Republic Act No. 11054, or the Bangsamoro Organic Law, is unconstitutional for allegedly violating the constitutional provisions on local autonomy, the creation of autonomous regions, and the powers granted to the Bangsamoro government. • Whether the Supreme Court may exercise judicial review over the constitutionality of the Bangsamoro Organic Law despite the political nature of the issues involved. RULING ACCORDINGLY, the application for the issuance of a temporary restraining order and/or writ of preliminary injunction in G.R. Nos. 242255 and 243246, and the Motion for Inhibition in G.R. No. 243246 are DENIED for lack of merit. The Petition in G.R. No. 242255 is PARTIALLY GRANTED. Republic Act No. 11054, in so far as it includes petitioner Province of Sulu in the Bangsamoro Autonomous Region, is declared VOID for being UNCONSTITUTIONAL. The Province of Sulu shall not be part of the Bangsamoro Autonomous Region. The Supreme Court partially granted the petition and declared the inclusion of the Province of Sulu in the BARMM unconstitutional. The Court ruled that under Article X, Section 18 of the 1987 Constitution, only the provinces, cities, and geographic areas that vote favorably in a plebiscite shall be

2022-2026 Case Digests and Doctrines Page 103 of 128 included in an autonomous region. Since the people of Sulu voted against the ratification of the Bangsamoro Organic Law, Sulu could not validly become part of the BARMM. However, the Court upheld the constitutionality of the remaining provisions of the Bangsamoro Organic Law. The invalidation was limited only to Sulu's inclusion, and the rest of the law remained effective under the doctrine of separability. The Court also held that the issues raised involved constitutional questions that were within the Court's power to review. The political significance of the Bangsamoro peace process did not prevent judicial examination of whether the law complied with the Constitution. The remaining provisions of Republic Act No. 11054, otherwise known as the Organic Law for the Bangsamoro Autonomous Region in Muslim Mindanao, based on the challenges raised in these petitions, are NOT UNCONSTITUTIONAL. RATIO DECIDENDI The Supreme Court emphasized that the Constitution requires the consent of the people of each affected political unit before they may be included in an autonomous region. The phrase "only those provinces, cities, and geographic areas voting favorably in such plebiscite shall be included in the autonomous region" means that each province or city must independently obtain the approval of its own electorate. The Court rejected the argument that Sulu's inclusion could be justified by the overall favorable vote of the former ARMM areas. The constitutional requirement does not allow the decision of other provinces and cities to override the will of a particular province that voted against inclusion. The Court explained that autonomy is based on the principle of self-determination, and the people of Sulu exercised their constitutional right to determine whether they wanted to be part of the new autonomous region. Allowing Sulu to remain within the BARMM despite its rejection would defeat the purpose of the plebiscite requirement. Nevertheless, the Court found no reason to invalidate the entire Bangsamoro Organic Law. The creation of BARMM, its governmental structure, and other provisions could continue to operate even without Sulu as part of the autonomous region. Therefore, only the unconstitutional inclusion of Sulu was removed.

2022-2026 Case Digests and Doctrines Page 104 of 128 G.R.No. 263828 Avelino C. Amangyen vs. the Commission on Elections and Franklin W. Talawec October 22, 2024 DOCTRINE Considering further that three years already passed from July 23, 2018, when an Entry of Judgment was made on Amangyen's conviction under Presidential Decree No. 705, until October 6, 2021, when he filed his COC for the 2022 NLE, Amangyen could not have represented by an honest mistake that he has not been "been found liable for an offense which carries with it the accessory penalty of perpetual disqualification to hold public office which has become final and executory." Due to the considerable lapse of time, such material misrepresentation cannot but be deemed intentional. FACTS OF THE CASE On November 2, 2021, as a registered voter in the Municipality of Paracelis, Talawec filed a Petition to Cancel Amangyen's COC on the ground of material misrepresentation for making the following entries:[6] Item 11. I am eligible for the office I seek to be elected to. Item 22. Have you ever been found liable for an offense which carries with it the accessory penalty of perpetual disqualification to hold public office which has become final and executory? Talawec argued that Amangyen misrepresented that he is eligible to run for public office and that he has never been found liable for an offense which carries with it the accessory penalty of perpetual disqualification because Amangyen was convicted for a violation of Presidential Decree No. 705 and was sentenced to suffer reclusion temporal in Criminal Case No. 2012-7-18-67 (For: Violation of Section 77 [formerly 68], of Presidential Decree No. 705, as amended)[7] titled, People of the Philippines v. Amangyen, before Branch 35, Regional Trial Court, Bontoc, Mountain Province (RTC Bontoc). This was later affirmed by the Court in G.R. No. 236892.[8] Pursuant to Articles 41 and 30 of the Revised Penal Code, the principal penalty of reclusion temporal carries with it the accessory of perpetual absolute disqualification, which deprives a person of the right to hold public office.[9] Additionally, Talawec alleged that Amangyen is disqualified to be a candidate pursuant to Section 12 of the Omnibus Election Code (OEC) after being sentenced to imprisonment for more than 18 months.

2022-2026 Case Digests and Doctrines Page 105 of 128 The Second Division of the COMELEC granted the Petition and cancelled Amangyen's COC. Amangyen filed a Most Respectful Motion for Reconsideration, claiming that the Petition must be summarily dismissed for being violative of the proscription in the COMELEC Rules of Procedure (COMELEC Rules) against invoking grounds other than false material misrepresentation and combining grounds for a separate remedy. Amangyen also insists that there are pending incidents in the criminal case filed against him. The COMELEC En Banc denied the Motion. On the merits, the COMELEC En Banc did not deviate from the findings of the COMELEC Second Division that Amangyen's conviction was already final and executory, brushing aside the argument that Cailin's motion for intervention before this Court was a pending incident which put on hold the finality of Amangyen's conviction. Amangyen ascribes grave abuse of discretion against the COMELEC En Banc mainly on the ground that the judgment of conviction against him is not yet final and executory. He contends that the pendency of the Petition for Correction/Determination of Proper Imposable Penalty,[26] dated April 21, 2022, and filed before the RTC Bontoc precluded the finality of his conviction. On November 29, 2021, in his verified Answer, Amangyen countered that his conviction has not yet attained finality because of a pending Motion for Intervention filed by one Johnny B. Cailin (Cailin) before the Supreme Court. ISSUE Whether the COMELEC acted with grave abuse of discretion in invoking its power to suspend or relax its procedural rules despite the alleged patent infirmity in Talawec's Petition for cancellation of Amangyen's COC and in granting the said Petition. RULING The Petition is dismissed. RATIO DECIDENDI

2022-2026 Case Digests and Doctrines Page 106 of 128 Power of the COMELEC to suspend or relax its procedural rules Talawec sought to cancel Amangyen's COC because the latter misrepresented that he has not been found liable for an offense which carries with it the accessory penalty of absolute perpetual disqualification. This pertains to Amangyen's qualification and eligibility to run for public office and is thus imbued with public interest. Thus, the COMELEC was justified in not summarily dismissing the Petition even if it was not filed on the exclusive ground that a material representation in Amangyen's COC is false. The electorate of the Municipality of Paracelis has the right to vote for a candidate who is eligible to run for public office. To this end, the COMELEC has the discretion to brush aside any technicality that will prevent it from cancelling the certificate of candidacy of someone who is disqualified by law.

2022-2026 Case Digests and Doctrines Page 107 of 128 G.R. No. 264125 Noel E. Rosal vs. Commission On Elections And Joseph San Juan Armogila/Oscar Robert H. Cristobal vs. Commission On Elections, Alfredo A. Garbin, Jr., Joseph San Juan Armogila, And Carmen Geraldine Rosal/Carmen Geraldine Rosal vs.Commission On Elections, Joseph San Juan Armogila, Alfredo A. Garbin, Jr., And Oscar Robert H. Cristobal/Jose Alfonso V. Barizo vs. Commission On Elections And Joseph San Juan Armogila October 22, 2024 DOCTRINE The prohibition under Section 261(v)(2) of the Omnibus Election Code is a preventive measure intended to insulate public funds from partisan political activities during the election period. The law punishes the actual release, disbursement, or expenditure of public funds for social welfare and development projects within the prohibited period, regardless of when such projects were approved or initiated. A "continuing" social welfare project is not exempt from the prohibition unless it falls within the specific statutory exceptions or has been authorized by the COMELEC after due notice and hearing. Moreover, liability under Section 261(v)(2) does not require proof of intent to influence voters or promote a candidacy. In contrast, disqualification for vote-buying under Section 68(a) of the Omnibus Election Code requires proof that money or material consideration was given for the purpose of influencing, inducing, or corrupting voters. FACTS OF THE CASE These are four consolidated Petitions for Certiorari 1 (Petitions) under Rule 65 in relation to Rule 64 of the Rules of Court, filed by petitioners Noel E. Rosal (Noel), Carmen Geraldine Rosal (Carmen), Jose Alfonso ,V. Barizo(Barizo ), and Oscar Robert H. Cristobal (Cristobal). All Petitions are with applications for the issuance of a temporary restraining order and/or writ of preliminary injunction. The petitions for disqualification alleged that Noel Rosal, Caren Rosal, and Barizo engaged in vote-buying under Section 68(a) of the Omnibus Election Code (OEC) and violated Section 261(v) of the OEC, which prohibits the release, disbursement, and expenditure of public funds within forty-five (45) days before a regular election. In G.R. No. 264125, Noel Rosal assailed the September 19, 2022 Resolution of the Commission on Elections (COMELEC) First Division, which granted the petition for

2022-2026 Case Digests and Doctrines Page 108 of 128 disqualification filed by Joseph San Juan Armogila and consequently disqualified him from running for the position of Governor of Albay in the May 9, 2022 National and Local Elections, as well as the November 18, 2022 Resolution of the COMELEC En Banc denying his motion for reconsideration. The COMELEC First Division found that the cash assistance payouts constituted a violation of Section 261(v)(2) of the OEC, which prohibits public officials and employees from releasing, disbursing, or expending public funds for social welfare and development projects and activities during the prohibited period. It rejected Noel's argument that the cash assistance program was exempt because it was merely a continuation of a program initiated in 2021, holding that the law does not provide an exemption for continuing social welfare and development projects, and that the exemption applies only to ongoing public works commenced before the campaign period or similar projects under foreign agreements. Nevertheless, despite finding Noel liable for violating Section 261(v)(2), the COMELEC First Division ruled that he was not guilty of vote-buying under Section 68(a) of the OEC, finding that the evidence showed that the recipients were aware that the amounts they received were due to them and were not intended to influence or induce them to vote for Noel Rosal. ISSUES • W/N COMELEC committed grave abuse of discretion amounting to lack or excess of jurisdiction in rendering its assailed Resolutions, which disqualified Noel, Carmen, and Barizo (collectively petitioners) from running in the May 9, 2022 NLE. • W/N COMELEC gravely abused its discretion in proclaiming Vice Governor Edcel Greco Lagman (Lagman) and Garbin to replace Noel and Carmen as Governor of Albay and Legazpi City Mayor, respectively. RULING There is grave abuse of discretion when a constitutional organ such as the COMELE makes manifestly gross errors in its factual inferences such that critical pieces of evidence, which have been nevertheless properly introduced by a party, or admitted, or which were the subject of stipulation, are ignored or not accounted for? A glaring misinterpretation of the constitutional text or of statutory provisions, as well as a misreading or misapplication of the current state of jurisprudence, is also considered

2022-2026 Case Digests and Doctrines Page 109 of 128 grave abuse of discretion. The arbitrariness consists in the disregard of the current state of our law. The Petition in G.R. No. 266796 is DISMISSED. The COMELEC Resolutions dated October 4, 2022 and May 4, 2023 in SPA No. 22-032 (DC) disqualifying Carmen Geraldine Rosal to run as Mayor in Legazpi City in the May 9, 2022 National and Local Elections are AFFIRMED In the petition of G.R. No. 266775 is DECONSOLIDATED from G.R. No. 264125, G.R. No. 266796, and G.R. No. 269274. Pro hac vice, COMELEC is directed, with dispatch, to separately docket a disqualification proceeding against Vice Mayor Oscar Robert H. Cristobal in order to determine whether he is also disqualified from running for the office of Vice Mayor in the 2022 National and Local Elections under Section 261(v)(2) in relation to Section 68 of the Omnibus Election Code. In the meantime, the Status Quo Ante Order issued by the Court on May 11, 2023 is hereby LIFTED with immediate effect. Accordingly, the assailed COMELEC Resolutions dated October 4, 2022 and May 4, 2023 in SPA No. 22-032 (DC) shall likewise immediately take effect. In G.R. No. 269274 is likewise DISMISSED and the COMELEC Resolutions dated May 5, 2023 and September 27, 2023 in SPA No. 22-030 (DC, disqualifying Jose Alfonso V. Barizo to run as Councilor in Legazpi City are AFFIRMED, with the MODIFICATION that the next highest-ranking Member of the Sangguniang Panlungsod be proclaimed to assume the vacated position of Jose Alfonso V. Barizo. The Supreme Court dismissed the petition of Noel Rosal and affirmed the COMELEC Resolutions disqualifying him from running for Governor of Albay in the May 9, 2022 National and Local Elections for violation of Section 261(v)(2) of the Omnibus Election Code. The Court held that COMELEC did not commit grave abuse of discretion in finding that Noel violated the prohibition against the release, disbursement, or expenditure of public funds during the prohibited period. However, the Court likewise held that COMELEC did not commit grave abuse of discretion in ruling that Noel was not guilty of vote-buying under Section 68(a) of the Omnibus Election Code because the evidence failed to establish that the cash assistance payouts were intended to influence, induce, or corrupt voters. RATIO DECIDENDI The Supreme Court held that Section 261(v)(2) of the Omnibus Election Code prohibits the release, disbursement, or expenditure of public funds for social welfare projects

2022-2026 Case Digests and Doctrines Page 110 of 128 during the prohibited election period, and that a continuing social welfare program is not exempt unless expressly provided by law. However, a violation of Section 261(v)(2) does not automatically constitute vote-buying under Section 68(a), as vote- buying requires proof that the money was given to influence or induce voters.

2022-2026 Case Digests and Doctrines Page 111 of 128 G.R No. 268891 GERARDO “JERRY” A. NOVERAS, PETITIONER Versus COMMISSION ON ELECTIONS AND NARCISO DELA CRUZ AMANSEC, RESPONDENTS October. 22, 2024 DOCTRINE A repeal may be expressed or implied. An express repeal is one wherein a statute declares, usually in its repealing clause, that a particular and specific law, identified by its number or title, is repealed. An implied repeal, on the other hand, transpires when a substantial conflict exists between the new and the prior laws. In the absence of an express repeal, a subsequent law cannot be construed as repealing a prior law unless an irreconcilable inconsistency and repugnancy exist in the terms of the new and the old laws. FACTS OF THE CASE On October 6, 2021, the petitioner, Gerardo “Jerry” A. Noveras, filed a certificate of candidacy (CoC) for the position of Vice-Governor of the province of Aurora in the May 9, 2022 general elections. On March 30, 2022, Narciso Dela Cruz Amansec, the respondent, visited Aurora Training Center compound, a provincial government facility, where he saw the campaign tarpaulins containing the name of Gerardo Noveras. Amansec questioned Tecuico, the one who made the printing of tarpaulins, and Amansec was met with hostility and aggressiveness. Amansec filed a police report and secured a search warrant that when invoked, the authorities were able to procure government-owned equipment and campaign tarpaulins and design templates containing the names of Gerardo Noveras and other candidates of his political slate. With this, Amansec filed a criminal complaint for violation of Section 261(o) of the Omnibus Election Code and Article 217 of the Revised Penal Code. On April 26, he also filed a Petition for Disqualification before the COMELEC, alleging that Noveras unlawfully used government resources for campaign purposes. Novares denied the allegation that his campaign materials were being printed on LGU premises using LGU resources. He also argued that violation of Section 261(o) is not

2022-2026 Case Digests and Doctrines Page 112 of 128 among the grounds for disqualification of a candidate under Sections 12 and 68 of the Omnibus Election Code or Section 40 of the Local Government Code. Despite the ongoing case filed by Amansec against Novares, in the May 9, 2022 elections, Novares won as the vice governor. On March 18, 2023, the Aurora provincial prosecutor’s office found probable cause to charge Novares and five other individuals with violation of Section 261(o) of the Omnibus Election Code; but on June 16, 2023, the Department of Justice modified the provincial prosecutor's ruling and dismissed the charge as against Novares. The COMELEC First Division resolved to grant the petition for disqualification, holding that Novares violated Sections 261(d)(1) and 261(e) of the Omnibus Election Code. Novares elevated the case to the Supreme Court, accusing COMELEC of grave abuse of discretion 1) construing Republic Act No. 7890 as a mere amendment of Section 261(d) of the Omnibus Election Code, contrary to the ruling in Javier; 2). disqualifying him on the basis of Section 261(d) despite its repeal by Republic Act No. 7890; and 3) disqualifying him on the basis of Section 261(e) despite the absence of evidence showing that he actually coerced or influenced Tecuico. ISSUE • Whether or not Section 261(d) of the Omnibus Election Code survived R.A No. 7890 and remained a basis for disqualification. • Whether COMELEC committed grave abuse of discretion in disqualifying Novares under Section 261(d) despite its repeal. • Whether substantial evidence supported disqualification under Section 261(e) for threats, intimidation, or use of fraudulent devices or schemes. RULING The present petition is PARTLY GRANTED. 1. Section 261(d) of the Omnibus Election Code overriding R.A No. 7890 as basis for disqualification • No. The Court ruled that the Section 261(d) of the Omnibus Election Code did not override R.A No. 7890 as the basis for determining disqualification. 2. Noveras’ Disqualification Despite Section 261(d)’s Repeal

2022-2026 Case Digests and Doctrines Page 113 of 128 • Yes. The Court ruled that COMELEC indeed committed a grave abuse of discretion in disqualifying Novares and using Section 261(d) as the backbone of its decision 3. Substantial Evidence • Yes. The Court affirmed that there was substantial evidence that Noveras utilized government resources and his authority over his subordinate for his own benefit. Hence, his disqualification under Section 261(e) deemed proper for the supported substantial evidence found. RATIO DECIDENDI Disqualification under Section 261(d) The COMELEC had indeed fallen short in properly assessing the proper and accurate provisions for grounds for disqualification. However, the Court sustained its ruling about Noveras’ disqualification because of the overwhelming substantial evidence of how Noveras indeed used the government’s resources and even went as far as using his authority over his subordinate for his own benefit that clearly is a course of deliberate actions and choices that exhibit the violation of Section 261(e).

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2022-2026 Case Digests and Doctrines Page 115 of 128 G.R. Number: 276456 PARTIDO FEDERAL NG PILIPINAS AND ITS NATIONAL PRESIDENT LEANDRO B. VERCELES, JR., AND ON HIS OWN BEHALF AS A PARTY MEMBERS, PETITIONERS, Versus COMMISSION ON ELECTIONS, REYNALDO S. TAMAYO, JR., THOMPSON C. LANTION AND GEORGE S. BRIONES, RESPONDENTS. February 25, 2025 DOCTRINE FACTS OF THE CASE The petitioners, Leandro B. Verceles Jr. and Antonio C. Rodriguez, filed a petition that aims to settle the political party’s intra-party dispute before the COMELEC on March 6, 2024, as the purported National President and Secretary-General, respectively, of Partido Federal ng Pilipinas (PFP). The petitioners cited Article IX-C, Section 2(5) of the 1987 Constitution to support their claim that the COMELEC has jurisdiction to resolve their petition. The petitioners aimed to have their supposed leadership confirmed by the COMELEC itself through the utilization of PFP's 2018 Constitution and By-Laws. In the same version of the PFP's Constitution, it was stated that the National Officers of the PFP are granted a two-year term, which could mean that the terms of the previous national officers who held the positions before them had expired on September 18, 2023, consequently making their election on December 14, 2023, valid and making them the legitimate National President and Secretary-General of the PFP. Reynaldo S. Tamayo Jr. and the other incumbent officers of the PFP countered that the governing document of the PFP was the 2022 PFP Constitution and By-Laws, which had been duly submitted to and recognized by the COMELEC and which provided for a three-year term for national officers, making the petitioners' claim invalid. Tamayo et al. argued that the election held on December 14, 2023, was invalid because it lacked proper notice, quorum, and authority. In addition to this was the submission of their SIUS on September 29, 2023, which was acknowledged by the COMELEC as valid. The COMELEC dismissed the petition for lack of merit, declaring that the 2022 Constitution and By-Laws governed the party, making the petitioners' claim about the

2022-2026 Case Digests and Doctrines Page 116 of 128 effectivity of the PFP's 2018 Constitution and By-Laws, and every decision based on it, invalid—which includes the petitioners' election and SIUS. The petitioners elevated the case to the Supreme Court through a Petition for Certiorari under Rule 64. ISSUE 1. Did the COMELEC gravely abuse its discretion in holding that the 2022 Constitution and By-laws of the PFP, providing for a three-year term for its National Officers, are the valid authoritative documents governing the party? 2. Did the COMELEC gravely abuse its discretion in ruling that Tamayo, et al. validly occupy the positions of President, Secretary General and General Counsel of the PFP? 3. Did the COMELEC gravely abuse its discretion in recognizing the SIUS filed by Tamayo, et al. on December 20, 2023? RULING The Petition for Certiorari is DENIED and the Resolution, dated September 6, 2024, and the Resolution, dated October 3, 2024, of the Commission on Elections En Banc in Case No. EM 24-002, are AFFIRMED. COMELEC’s Alleged Grave Abuse of Discretion In Holding the 2022 Constitution and By-laws of the PFP The Court finds no indication that the COMELEC exceeded its discretion in a manner so unreasonable as to meet the threshold for exception, which would justify the Court's review of the factual issues. Furthermore, the petitioners' claim that the COMELEC also gravely abused its discretion by addressing the issues of holdover authority, notice, and quorum is also without merit. Therefore, the Court finds the COMELEC's ruling regarding the 2022 Constitution and By-Laws as the prevailing authoritative documents governing the PFP to have merit, as such ruling is supported by substantial evidence. RATIO DECIDENDI: Article IX-C, Section 2(5) of the 1987 Constitution The Supreme Court ruled in favor of the COMELEC's ruling, clarifying that the COMELEC did not commit grave abuse of discretion in recognizing and upholding the 2022 PFP Constitution and By-Laws, which grants the incumbent officers the right

2022-2026 Case Digests and Doctrines Page 117 of 128 to remain the legitimate national officers of the said political party. Pursuant to its constitutional power under Article IX-C, Section 2(5) of the 1987 Constitution, the COMELEC has the authority and duty to determine the legitimate officers of a political party as an exercise of its power to register political parties and resolve intra- party leadership disputes.

2022-2026 Case Digests and Doctrines Page 118 of 128 G.R. Nos. 260219 & 260231 Datu Pax Ali versus Commission on Elections April 22, 2025 DOCTRINE Residence for election purposes is synonymous with domicile. To successfully acquire a new domicile, a candidate must establish by clear and positive proof: (1) bodily presence in the new locality; (2) intent to remain therein (animus manendi); and (3) intent to abandon the old domicile (animus non revertendi). On material misrepresentation, the Court emphasized that cancellation of a Certificate of Candidacy under Section 78 of the Omnibus Election Code requires a deliberate and false representation concerning a qualification for public office. Most importantly, the Court abandoned the judicially created Second Placer Rule and held that: When a winning candidate is subsequently disqualified or his or her Certificate of Candidacy is cancelled after the elections, the resulting permanent vacancy should be filled through the rule on succession under the Local Government Code rather than by proclaiming the second placer. FACTS OF THE CASE On October 7, 2021, Datu Pax Ali S. Mangudadatu, then incumbent Mayor of Datu Abdullah Sangki, Maguindanao, filed his Certificate of Candidacy (COC) for Governor of Sultan Kudarat in the 2022 National and Local Elections. In his COC, he declared that he had been a resident of Sultan Kudarat for one year and eight months immediately preceding the elections. Subsequently, separate petitions to deny due course to or cancel his COC were filed by Sharifa Akeel Mangudadatu, Azel V. Mangudadatu, and Bai Ali A. Untong. They alleged that Pax Ali falsely represented his residency qualification because he continued to act and serve as Mayor of Datu Abdullah Sangki, Maguindanao, thereby showing that he had not abandoned his domicile there. In his defense, Pax Ali asserted that he had already established domicile in Sultan Kudarat, citing his voter registration transfer, government-issued identifications,

2022-2026 Case Digests and Doctrines Page 119 of 128 affidavits, certifications, and actual residence in the province. He later resigned as Mayor on November 15, 2021. Thereafter, the COMELEC First Division granted the petitions and cancelled Pax Ali's COC for material misrepresentation. The COMELEC En Banc affirmed the ruling, finding that he failed to validly establish a new domicile in Sultan Kudarat and, consequently, failed to satisfy the one-year residency requirement for governor. Pax Ali elevated the matter to the Supreme Court through petitions for certiorari, alleging that COMELEC committed grave abuse of discretion in cancelling his COC. ISSUE Whether the COMELEC En Banc committed grave abuse of discretion amounting to lack or excess of jurisdiction in cancelling the Certificate of Candidacy of Datu Pax Ali S. Mangudadatu for material misrepresentation as to his residency qualification for Governor of Sultan Kudarat. RULING No. The COMELEC En Banc did not commit grave abuse of discretion in cancelling Pax Ali's Certificate of Candidacy. RATIO DECIDENDI The Court held that COMELEC correctly found that Pax Ali failed to establish all the requisites necessary for a valid change of domicile. The Court reiterated that residence for election purposes is synonymous with domicile and that a candidate claiming a new domicile must prove not only actual residence and intent to remain, but also the abandonment of the former domicile. Such change cannot be presumed and must be established through clear and positive evidence. Although the Court acknowledged that Pax Ali presented evidence showing physical presence in Sultan Kudarat, it agreed with COMELEC that his continued exercise of the functions of Mayor of Datu Abdullah Sangki negated any clear intent to abandon his domicile in Maguindanao. His acts, viewed in their totality, failed to establish animus non revertendi or the intention to abandon his former residence.

2022-2026 Case Digests and Doctrines Page 120 of 128 The Court found significant the fact that Pax Ali continued to occupy and discharge the duties of his office as Mayor until November 15, 2021. Such conduct was inconsistent with his claim that he had already transferred his domicile to Sultan Kudarat as early as 2020. Accordingly, the Court sustained COMELEC's finding that Pax Ali did not meet the one-year residency requirement under Section 39(a) of the Local Government Code. Since residency is a qualification for the office sought, his declaration in the COC constituted a false material representation. The Court thus held that COMELEC acted within its jurisdiction and on the basis of substantial evidence when it cancelled his COC under Section 78 of the Omnibus Election Code. Consequently, no grave abuse of discretion could be attributed to the Commission.

2022-2026 Case Digests and Doctrines Page 121 of 128 G.R. No. 277280 FRANCIS LEO ANTONIO MARCOS versus COMMISSION ON ELECTIONS September 30, 2025 DOCTRINE: The case reiterates the doctrine of mootness in election controversies, particularly when a candidate who challenges a COMELEC ruling subsequently withdraws his candidacy. The Court held that the withdrawal of a candidacy extinguishes the actual controversy regarding the validity of the COMELEC's declaration of nuisance candidacy, leaving no justiciable issue for judicial determination. As explained by the Court: A case or issue is considered moot and academic when it ceases to present a justiciable controversy by virtue of supervening events, so that an adjudication of the case or a declaration on the issue would be of no practical value or use. In such instance, there is no actual substantial relief which a petitioner would be entitled to, and which would be negated by the dismissal of the petition. The Court further stressed that exceptions to the mootness doctrine are strictly construed: Where an issue is moot on its face, the application of any of the exceptions should be subjected to a strict test because it is a deviation from the general rule. FACTS OF THE CASE: On October 8, 2024, Francis Leo Antonio Marcos filed his Certificate of Candidacy (COC) for Senator in the May 12, 2025 National and Local Elections as an independent candidate. He had previously run for the Senate in 2022 and garnered 4,477,024 votes. Subsequently, the COMELEC Law Department filed a petition to declare Francis a nuisance candidate, alleging that he lacked political affiliation, ideology, and a genuine platform, that he was not serious in his candidacy because he filed his COC through a representative, and that his surname "Marcos" could cause voter confusion. In his defense, Francis argued that a similar petition against his 2022 candidacy had already been dismissed by COMELEC, that he possessed substantial public support

2022-2026 Case Digests and Doctrines Page 122 of 128 and a platform focused on education and agriculture, and that COMELEC rules expressly allow the filing of a COC through an authorized representative. Thereafter, the COMELEC Second Division declared Francis a nuisance candidate and cancelled his COC. The COMELEC En Banc affirmed the ruling and denied his Motion for Reconsideration. Aggrieved, Francis filed a Petition for Certiorari before the Supreme Court, alleging that COMELEC gravely abused its discretion and violated his rights to due process and equal protection. On January 21, 2025, the Supreme Court issued a TRO preventing COMELEC from enforcing its ruling. However, shortly thereafter, Francis filed a Statement of Withdrawal of his candidacy. The COMELEC subsequently gave due course to the withdrawal and removed his name from the list of senatorial candidates. ISSUE Whether the COMELEC En Banc committed grave abuse of discretion amounting to lack or excess of jurisdiction in declaring Francis Leo Antonio Marcos a nuisance candidate and cancelling his Certificate of Candidacy. RULING: The Court did not determine whether COMELEC committed grave abuse of discretion. Instead, it dismissed the Petition for being moot and academic. RATIO DECIDENDI The Court held that the issue of whether the COMELEC En Banc gravely abused its discretion in declaring Francis a nuisance candidate became moot upon his withdrawal of candidacy. The Petition sought the annulment of the COMELEC En Banc Resolution affirming the cancellation of Francis' Certificate of Candidacy and declaring him a nuisance candidate. However, after the filing of the Petition and the issuance of a Temporary Restraining Order, Francis voluntarily withdrew his candidacy for Senator. As a consequence, there no longer existed an actual controversy requiring judicial resolution. The Court explained:

2022-2026 Case Digests and Doctrines Page 123 of 128 "Francis' withdrawal of his candidacy rendered the Petition, which sought to determine whether the COMELEC committed grave abuse of discretion in declaring Francis a nuisance candidate, moot, and academic." Citing settled jurisprudence, the Court reiterated: "A case or issue is considered moot and academic when it ceases to present a justiciable controversy by virtue of supervening events, so that an adjudication of the case or a declaration on the issue would be of no practical value or use." The Court further held that none of the recognized exceptions to the mootness doctrine justified a review of the COMELEC resolutions. It emphasized that: "Where an issue is moot on its face, the application of any of the exceptions should be subjected to a strict test because it is a deviation from the general rule." Applying this standard, the Court concluded: "None of the exceptions are present here. With the withdrawal of Francis' candidacy, there is no longer a continuing controversy, and any declaration on the subject would be of no practical value. To resolve the case would be a useless exercise and will result in an opinion on a hypothetical situation." Accordingly, the Court dismissed the Petition and refrained from ruling on whether the COMELEC En Banc correctly declared Francis Marcos a nuisance candidate or whether it gravely abused its discretion in cancelling his Certificate of Candidacy.

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2022-2026 Case Digests and Doctrines Page 125 of 128 G.R.No. 279413 Errol B. Comafay, Jr., vs. Commission on Elections and Paquintos B. Sallaya January 14, 2026 DOCTRINE To justify the cancellation of a Certificate of Candidacy (COC) under Section 78 of the Omnibus Election Code, the false representation must be material and made with a knowingly deliberate intent to deceive the electorate regarding the candidate's qualifications for public office. Minor, harmless omissions, structural syntax issues, or typographical errors (such as a missing comma) that do not affect the candidate's actual qualifications or mislead the voters do not amount to material misrepresentation. FACTS OF THE CASE On October 6, 2024, Comafay, Jr. filed his COC4 for the position of Member, Sangguniang Panlungsod of Tabuk City, Kalinga in the May 12, 2025 National and Local Elections. In Comafay, Jr.'s COC, he indicated the following information as his residence/address- Province: "KALINGA"; Municipality: "TABUK"; Barangay: "BULANAO"; and House No./Street/Subdivision: "TARAKI NATIONAL RD PUROK 5".6 Furthermore, Comafay, Jr. indicated "TARAKI, NATIONAL RD, PUROK 5, BRGY. BULANAO, TABUK CITY, KALINGA" as his address for election purposes.7 Sallaya argued that the COC of Comafay, Jr. contained material misrepresentation within the latter indicated "Taraki National Road, Purok 5, Bulanao, Tabuk City, Kalinga" as residence/mailing address, when in fact no "Taraki National Road" exists in Barangay Bulanao or anywhere in Tabuk City, Kalinga.11 To support his argument, Sallaya attached a Certification 12 from the Office of the Punong Barangay of Barangay Bulanao, Tabuk City, Kalinga certifying that no Taraki National Road existed within their jurisdiction. 13 In other words, Sallaya faulted Comafay, Jr. for omitting a comma in his residence address. Comafay, Jr. countered that he had no intent to deceive the voters and that he had consistently used "Taraki, National Rd, Brgy. Bulanao, Tabuk City" in his official identification documents (such as his Unified Multi-purpose ID), Personal Data Sheet, and SALN for over a decade, where "Taraki" referred to the Taraki Building where he resided.

2022-2026 Case Digests and Doctrines Page 126 of 128 The COMELEC Second Division granted Sallaya's petition, ruling that the lack of a comma created a false address ("Taraki National Road") which amounted to a deliberate and material misrepresentation. This was subsequently affirmed by the COMELEC En Banc. Comafay, Jr. filed a Petition for Certiorari under Rule 64 before the Supreme Court. The Supreme Court ruled that petitioner did not commit any materially false and deceptive representation in his COC in relation to his residence qualification. COMELEC gravely erred in ruling that the lack of a comma amounted to a false material representation, despite the substantial evidence presented by petitioner showing good faith and consistency as to his declared residence address. ISSUES The issue is whether the COMELEC gravely abused its discretion when it ruled that petitioner's address as indicated in his COC was a material misrepresentation. RULING NO. The Supreme Court granted the Petition for Certiorari and reversed the Resolutions of the COMELEC. The Court ruled that the COMELEC resorted to an "overly literal and narrow interpretation" of what constitutes a material misrepresentation. The omission of a comma was a harmless typographical/clerical oversight that did not alter the substance of his address or deceive the electorate. The Court found no bad faith or intent to deceive on the part of Comafay, Jr., since he clearly stated his correct address with proper punctuation in another section of the same document. Furthermore, he presented proof that he had consistently and in good faith utilized the same residential address in all his public and private transactions for over ten years. Because the error did not affect or falsify his eligibility and qualifications (such as his actual residency in Tabuk City), it cannot be used to cancel his COC. RATIO DECIDENDI 1. Honest Disclosure Negates Deceit

2022-2026 Case Digests and Doctrines Page 127 of 128 • The Logic: A Certificate of Candidacy (CoC) cannot be canceled for misrepresentation if the exact truth is transparently visible within the very same document. • The Application: While the candidate missed a comma in one section of the form (writing "TARAKI NATIONAL RD PUROK 5"), he filled out his address completely and properly with all required punctuation in another part of the exact same form. Because the complete geographical breakdown was openly visible on the same page, there was no intent to hide information or deceive the public. 2. Typographical Slips Are Not Disqualifying Lies • The Logic: Punctuation adjustments or grammatical oversights do not change a candidate’s physical reality or alter their substantive legal qualifications to run for public office. • The Application: The Court clarified that omitting a single comma is nothing more than an innocent, harmless clerical error. It does not modify where the candidate actually resides, nor does it generate a fictitious location out of thin air to manipulate election parameters. The Supreme Court ruled that a missing comma in a Certificate of Candidacy's residential address is an innocuous mistake, not a false material representation justifying cancellation. The Court found that omitting the comma did not constitute deceit and should not be treated as a material misrepresentation.

2022-2026 Case Digests and Doctrines Page 128 of 128 G.R. No. 279008 258MERSON C. CALUBAG, PETITIONER, VS. COMMISSION ON ELECTIONS AND KIMBERLY P. JOSEPH, RESPONDENTS. April 8, 2026