Title
Albana vs. Belo
Case
G.R. No. 158734
Decision Date
Oct 2, 2009
Elected officials in Panitan, Capiz, faced disqualification and criminal charges for alleged election offenses; Supreme Court upheld criminal charges but nullified disqualification due to procedural errors.
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Case Digest (G.R. No. 158734)

Facts:

Election Context: During the May 14, 2001 elections, petitioners Roberto AlbaAa, Katherine Belo, Generoso Derramas, Vicente Duran, Ricardo Araque, Merlinda Degala, Gabriel Aranas, Ernesto Bito-on, and Juvic Deslate were elected as Mayor, Vice-Mayor, and Members of the Sangguniang Bayan of Panitan, Capiz, respectively.

Complaint Filed: On June 23, 2001, private respondents (Pio Jude S. Belo, Rodolfo Deocampo, and Lorencito Diaz) filed a complaint with the COMELEC Law Department, accusing petitioners of election offenses, including terrorism (violation of Section 261(e) of the Omnibus Election Code) and vote-buying (violation of Section 261(a) of the Omnibus Election Code). The complaint also sought disqualification of petitioners from holding office under Section 68 of the Omnibus Election Code and Section 6 of Republic Act No. 6646.

COMELEC Action: The COMELEC Law Department found prima facie evidence and recommended the filing of an Information for election offenses and disqualification of petitioners. On February 28, 2003, the COMELEC En Banc directed the filing of criminal charges and docketed the disqualification case. Petitioners filed a motion for reconsideration, which was denied on June 3, 2003, for being filed out of time and lacking merit.

Related Case: In a related case, AlbaAa v. Commission on Elections (G.R. No. 163302), the Supreme Court nullified the COMELEC’s resolution disqualifying petitioners, holding that the complaint for disqualification should have been dismissed pursuant to COMELEC Resolution No. 2050, as petitioners had already been proclaimed winners.

Issue:

  1. Whether the COMELEC En Banc erred in finding probable cause against petitioners for election offenses.
  2. Whether the COMELEC violated petitioners’ constitutional rights to due process by addressing the issue of disqualification.
  3. Whether the COMELEC resolution complied with constitutional requirements for clarity and factual basis.
  4. Whether petitioners’ motion for reconsideration was timely filed.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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