Case Digest (G.R. No. 261107)
Facts:
The case involves Ana Liza Arriola Peralta (petitioner) against the Commission on Elections (COMELEC), represented by its Campaign Finance Unit (respondent). The events leading to this case began when Peralta ran for Mayor of San Marcelino, Zambales, during the May 10, 2010 National and Local Elections (2010 NLE). At that time, the municipality had 20,301 registered voters. On October 1, 2014, Atty. Ferdinand T. Rafanan, Head of the Campaign Finance Unit of COMELEC, informed Peralta that she had spent PHP 285,500.00 according to the Statement of Contributions and Expenditures (SOCE) she submitted on June 7, 2010. The maximum allowable expenditure for her campaign, as per Section 100 of the Omnibus Election Code (OEC), was PHP 3.00 per registered voter, totaling PHP 60,903.00. Consequently, Atty. Rafanan requested an explanation from Peralta regarding the apparent overspending.
In her response dated March 2, 2015, Peralta provided affidavits from her contributors, explaining...
Case Digest (G.R. No. 261107)
Facts:
Background of the Case
Ana Liza A. Peralta (petitioner) ran for Mayor in the Municipality of San Marcelino, Zambales, during the May 10, 2010 National and Local Elections (2010 NLE). The municipality had 20,301 registered voters at the time.
Allegations of Overspending
In a letter dated October 1, 2014, the COMELEC’s Campaign Finance Unit informed petitioner that she had exceeded the allowable campaign expenditure limit. Petitioner reported spending PHP 285,500.00 in her Statement of Contributions and Expenditures (SOCE), while the maximum allowed under Section 100 of the Omnibus Election Code (OEC) was PHP 3.00 per registered voter, or PHP 60,903.00.
Petitioner’s Defense
In her response, petitioner claimed that errors were made in her SOCE, particularly in the categorization and amounts of contributions. She submitted affidavits from contributors correcting the errors, arguing that her actual expenditures were only PHP 51,500.00, well within the legal limit. She also cited her limited mobility due to a hip fracture surgery as a reason for the delayed verification of contributions.
COMELEC’s Action
Despite petitioner’s explanation, the COMELEC filed a complaint against her for election overspending on May 9, 2015. After a preliminary investigation, the COMELEC found probable cause to charge petitioner and issued Resolution No. 18-0656 on August 8, 2018. Petitioner’s motion for reconsideration was denied in Resolution No. 21-0472-57 on July 14, 2021.
Issue:
- Whether there was inordinate delay in the conduct of the preliminary investigation, violating petitioner’s right to speedy disposition of cases.
- Whether the COMELEC committed grave abuse of discretion in finding probable cause to charge petitioner with election overspending.
Ruling:
The Court granted the petition, nullifying the COMELEC’s resolutions and dismissing the complaint against petitioner.
Inordinate Delay
The Court found that the preliminary investigation took more than six years, from the filing of the complaint on May 9, 2015, to the resolution of the motion for reconsideration on July 14, 2021. This delay violated petitioner’s constitutional right to a speedy disposition of cases. The COMELEC failed to justify the delay or show compliance with its prescribed procedures.
No Grave Abuse of Discretion
Given the finding of inordinate delay, the Court did not address the merits of the election overspending charge.
Ratio:
- Right to Speedy Disposition of Cases – The Constitution guarantees the right to a speedy disposition of cases, which extends to all judicial, quasi-judicial, and administrative proceedings. Inordinate delay in the resolution of a case, especially without justification, violates this right and warrants dismissal of the case.
- Burden of Justifying Delay – When delays occur beyond prescribed periods, the burden shifts to the prosecuting body to justify the delay. The COMELEC failed to meet this burden, as the case did not involve complex issues or voluminous evidence.
- Prejudice to the Accused – Prolonged proceedings can impair the accused’s defenses and cause unnecessary mental anguish. In this case, the delay prejudiced petitioner, making dismissal appropriate.