Comelec, reversed by SC on vote-buying case

The Supreme Court, en banc, reversed the Comelec on a disqualification case filed against the Cagayan governor for alleged massive vote-buying. The petition to disqualify was filed on the day when the winner was proclaimed. The highest court of the land ruled that the Comelec was wrong. The petition should have been given due course.

The province of Cagayan is the regional center of region 2, or the Cagayan Valley region, and it is one of the biggest provinces in northern Luzon. Its incumbent governor Manuel Mamba won the last elections and was proclaimed on May 10, 2022. His opponent, Maria Zara Rose de Guzman-Lara filed a petition to disqualify Mamba on the ground of alleged massive vote-buying and supposed illegal disbursement of public funds. In the said petition, Lara prayed that the Comelec order the Provincial Board of Canvasser to hold in abeyance the proclamation of Mamba.

But on May 11, 2022, the provincial board of canvassers of Cagayan proclaimed Mamba. He was also the incumbent governor having been elected in 2019. He was being accused of disbursing public funds during the election period. The petitioner Lara alleged that Mamba was violating Section 68 of the Omnibus Election Code. Lara alleged that Mamba was using public funds and distributed them in the form of "ayuda" during the election period.

On December 22, 2024, the Comelec, Second Division granted Lara's petition, ruling that Mamba was disqualified based on the ground relied upon by the petitioner. On appeal, the Comelec, en banc, reversed the decision of the Comelec, Second Division, based on technicality, holding that the petition to disqualify was filed out of time. The Comelec, en banc held that Lara's petition was filed on May 10, 2022 at 6:21 pm or beyond office hours. Thus, it was deemed filed on May 11, 2022.

It was the Comelec- en banc's determination that, based on the provision of law, once a winning candidate is proclaimed, the Comelec loses jurisdiction over the case. On April 5, 2023, Lara filed a petition with the Supreme Court assailing the decision of the Comelec, en banc, The Supreme Court, en banc, with Justice Joseph Lopez writing the decision, held that the Comelec was wrong and that the petition should have been given due course.

The Supreme Court held that the Comelec has interpreted the law very literally and very technically. The elections body was deemed to have lost sight of the peculiar nature of election cases. The High Court reminded the Comelec that "election cases are, at all times, invested with public interest, which cannot be defeated by mere procedural or technical infirmities." The Supreme Court declared that technical rules should be relaxed to give way to substantive justice.

Declared the Court in this case of Lara vs Mamba, or GR no 265847, decided on August 6, 2024, but released only last month: "Time and again, this Court has chosen to uphold the relaxation of election procedural rules in the interest of substantial justice.'' Citing its own decision in Uy vs Comelec, where the greater interest of justice was given primacy over procedural rules, the Supreme Court ordered that this case of Lara vs Mamba be remanded to the Comelec for resolution on the merits.

However, by the time the ruling of the Comelec shall have been issued, the May 12, 2025 elections shall have already been held and the winner proclaimed. Whatever results of that remanded case shall then become moot and academic. Nonetheless, the highest court has emphasized the principle of substantive justice being primordial over technicality. And that is what matters most.