Facts:

This case involves Mayor Agnes Villanueva, the current member of the Sangguniang Panlalawigan of Misamis Occidental, as the petitioner against the Honorable Commission on Elections (COMELEC) and its Law Department, both in Manila. The petition was filed in relation to two resolutions issued by the COMELEC: one on December 11, 2015, and another on January 21, 2022. These resolutions found probable cause to indict Villanueva for violating Section 261(f) of the Omnibus Election Code (OEC) and instructed the COMELEC Law Department to file the appropriate charges. Villanueva served as mayor of Plaridel, Misamis Occidental from 2010 until her election to the provincial council in 2019.

The facts surrounding the complaint began in October 2010 when Villanueva requested the reassignment of the municipal election officer, Amado B. Quiza, citing disregard of voter registration procedures and abuse of authority. Following her letter, Villanueva ordered the closure of the municipal electio

...

Facts:

Background of the Case

• Mayor Agnes Villanueva, formerly mayor of Plaridel, Misamis Occidental (2010–2019), is now an incumbent member of the Sangguniang Panlalawigan of Misamis Occidental.
• Villanueva initiated proceedings by petitioning the COMELEC to reassign the municipal election officer, Amado B. Quiza, citing multiple grounds:

- Disregard of proper voter registration procedures leading to the proliferation of flying voters. - Neglect in screening voter registrants. - Alleged abuse of authority in demoting a Board of Election Inspectors (BEI) chairperson who reported threats and harassment during the barangay and Sangguniang Kabataan elections.

Administrative and Communicative Developments

• Villanueva first ordered the closure of the existing municipal election office on November 15, 2010; later she modified her position by allowing Quiza to work under revised arrangements until December 31, 2010.
• Through subsequent correspondence with Regional COMELEC Director Renato A. Magbutay (letters dated January 26 and 28, 2011), the issue of office space was discussed, with Villanueva asserting that the responsibility for providing office space rests with the COMELEC pursuant to Section 55 of the Omnibus Election Code (OEC).
• On February 15, 2011, the COMELEC Law Department (CLD) instituted the present complaint for violation of Section 261(f) of the OEC, alleging that Villanueva’s unilateral closure disrupted the performance of official duties.
• Villanueva, in her Answer, maintained that her actions were justified by the COMELEC’s inaction on her reassignment request and that the closure was a temporary measure tailored to address her grievances against Quiza.
• Instead of filing a Supplemental Answer to a subsequent order on March 17, 2011, Villanueva opted to file a “Motion to Dismiss and Additional Evidence” on April 15, 2011.

Prosecution and COMELEC Actions

• On April 27, 2015, the CLD formally recommended the filing of charges against Villanueva, emphasizing that:

- The closure of the municipal election office disrupted the functions and duties of the election officer and his staff. - Villanueva’s act demonstrated an intent to coerce the COMELEC into reassigning Quiza, rather than pursuing proper legal remedies.

Petition for Certiorari and Subsequent Developments

• On April 28, 2022, Villanueva filed a Verified Petition for Certiorari seeking:

- The nullification of the December 11, 2015 and January 21, 2022 resolutions. - A preliminary injunctive writ to stop the CLD from filing an information against her. - Section 261(f) of the OEC can only be committed during an election period. - The filing of charges is barred by prescription. - There was inordinate delay in the COMELEC’s actions (taking almost six years on certain motions and an overall pendency of eleven years). - Her actions were in good faith, as evidenced by the subsequent dismissal of related administrative and criminal complaints by the Office of the Ombudsman.

Arguments of the Solicitor General (OSG) on Behalf of COMELEC

• The petition was filed out of time according to the prescribed 30-day period under Rule 64, Section 3.
• The OSG stressed that, unlike other election offenses, Section 261(f) has no temporal limitation and may be committed outside an election period.
• The COMELEC’s prosecutorial discretion in handling election offenses was to be respected, and any defense regarding inordinate delay raised only at the preliminary investigation stage was considered waived.

Issue:

Procedural Timeliness

• Whether Villanueva’s petition for certiorari was filed within the period prescribed by Rule 64, Section 3, given that notice of the first resolution was received on February 1, 2016, and the petition was filed on April 19, 2022.
• Whether the miscalculation of the notice period (relying on the date of the second assailed resolution) renders the petition untimely.

Interpretation of Section 261(f) of the OEC

• Whether the offense of coercing election officials and employees under Section 261(f) is limited to acts committed during an election period, or can be committed outside the election period.
• The scope and meaning of the term “election functions and duties” as used in the provision.

Abuse of Discretion and Inordinate Delay

• Whether the COMELEC’s prolonged delay in determining probable cause—spanning nearly eleven years—amounts to grave abuse of discretion.
• Whether such inordinate delay violates Villanueva’s constitutional right to speedy disposition of cases.

Merits of the Substance Versus Technical Infirmity

• Although there is a procedural defect regarding timeliness, whether the substantive merits of Villanueva’s arguments justify the relaxation of the strict procedural rule.

---

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)