Facts:

The case involves a petition for review on certiorari filed by Roberto AlbaAa, Katherine Belo, Generoso Derramas, Vicente Duran, Ricardo Araque, Merlinda Degala, Gabriel Aranas, Ernesto Bitoon, and Juvic Deslate (collectively referred to as "petitioners") against Pio Jude S. Belo, Rodolfo Deocampo, and Lorencito Diaz (collectively referred to as "respondents"). The petition was filed on October 2, 2009, challenging the Commission on Elections (COMELEC) En Banc Resolution dated February 28, 2003, which found probable cause against the petitioners for election offenses, specifically violations of Section 261(a) and (e) of the Omnibus Election Code, in relation to Sections 28 and 68 of Republic Act No. 6646. The case arose from the May 14, 2001 elections in the Municipality of Panitan, Capiz, where the petitioners were elected and proclaimed as municipal officials on May 18, 2001. Following their proclamation, the respondents filed a complaint with the COMELE...

Facts:

Election and Proclamation

• On May 14, 2001, both petitioners and private respondents vied for positions of Mayor, Vice-Mayor, and Members of the Sangguniang Bayan in the Municipality of Panitan, Capiz.
• The petitioners—Roberto Albaaa, Katherine Belo, Generoso Derramas, Vicente Duran, Ricardo Araque, Lilia Aranas, Merlinda Degala, Gabriel Aranas, Ernesto Bito-on, and Juvic Deslate—were duly elected and proclaimed winners on May 18, 2001.
• Private respondents, having contested the integrity of the election process, later sought to disqualify the petitioners by invoking allegations against them.

Allegations and Complaint Filing

• On June 23, 2001, private respondents filed a complaint before the COMELEC Law Department alleging acts of terrorism (Section 261(e)) and vote-buying (Section 261(a)) committed by petitioners.
• The complaint additionally sought the disqualification of the petitioners under Section 68 of the Omnibus Election Code and Section 6 of Republic Act No. 6646.
• The Law Department found a prima facie case and recommended that an Information be filed against the petitioners alongside recommending their disqualification.

COMELEC’s Administrative Proceedings

• Acting upon the recommendation, on February 28, 2003, the COMELEC En Banc issued a Resolution directing its Law Department to file the necessary criminal Information against the petitioners while also docketing the electoral aspect of the complaint as a disqualification case.
• Petitioners filed a motion for reconsideration, arguing that the COMELEC failed to state clear findings of fact and error in docketing the electoral complaint as a disqualification case, among other procedural deficiencies.
• On June 3, 2003, the COMELEC denied the motion for reconsideration on the basis of lack of merit and untimeliness.
• Subsequently, on October 21, 2003, the COMELEC First Division rendered a resolution annulling the petitioners’ proclamation on the ground of violations of Sections 261(a) and (e) of the Omnibus Election Code.
• In a related case (AlbaAa v. COMELEC, G.R. No. 163302), the Supreme Court had earlier nullified the proclamation of petitioners as duly-elected officials, setting a precedent for the ensuing proceedings.

Petition for Review and Contested Arguments

• Petitioners sought review on certiorari under Rule 45, challenging the COMELEC Resolutions dated February 28, 2003 and June 3, 2003.
• Their major contentions included:
• The COMELEC improperly relied on affidavits of dubious credibility that were not based on personal knowledge and were not directly related to the May 2001 elections.
• The filing of disqualification proceedings was procedurally erroneous because, under COMELEC Resolution No. 2050, a complaint for disqualification should be dismissed when filed after a candidate has been proclaimed.
• Violation of due process occurred due to the failure of the resolution to clearly state the factual and legal bases for the finding of probable cause.
• The timeliness of the motion for reconsideration was disputed, with petitioners claiming compliance with procedural rules.

Responses and Supporting Arguments by Other Parties

• Private respondents asserted that the evidence, particularly the sworn affidavits, demonstrated widespread vote-buying, terrorism, and intimidation during the elections.
• They maintained that the COMELEC’s finding of probable cause was substantiated by the evidence and that the procedural act of docketing the complaint as a disqualification case was within the Commission’s purview.
• The Office of the Solicitor-General likewise filed a comment upholding the finding of probable cause and the proper conduct of the COMELEC.

Issue:

Whether the COMELEC correctly found probable cause to prosecute the petitioners for election offenses under Sections 261(a) and (e) of the Omnibus Election Code.

• Did the affidavits and evidence on record sustain a prima facie case for terrorism, vote-buying, and other alleged malpractices?
• Was the determination of probable cause exercised within the bounds of COMELEC’s discretionary power?

Whether the COMELEC erred in docketing the electoral aspect of the complaint as a disqualification case.

• Does COMELEC Resolution No. 2050 mandate the dismissal of a disqualification complaint when the candidate has already been proclaimed, thus rendering the docketing order defective?
• Were the procedural and substantive rules for disqualification properly followed?

Whether the motion for reconsideration of the COMELEC’s Resolution was timely filed and rightly denied on merit.

• Did petitioners comply with the prescribed period for filing a motion for reconsideration?
• Were the arguments raised in the motion for reconsideration substantial and distinct, or merely rehashing earlier contentions?

Whether the petitioners’ constitutional right to due process, including adequate notice and a clear statement of evidence and legal bases, was observed in the COMELEC resolutions.

• Did the resolution clearly and distinctly outline both the findings of fact and the applicable law, thereby meeting the requirements of Article VIII, Section 14 of the Constitution?
• Was there any legal or factual basis to sustain the claims of due process violation?

Whether petitioners availed themselves of the proper remedial measures or if the petition for review on certiorari was misdirected.

• Was the petition for review the proper remedy for contesting the resolutions of COMELEC?
• Can new issues be raised at the appellate stage regarding the choice of remedy?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)