Title
Bedol vs. Commission on Elections
Case
G.R. No. 179830
Decision Date
Dec 3, 2009
Lintang Bedol, Maguindanao PBOC Chair, failed to attend canvassing, lost election documents, and defied COMELEC, leading to contempt conviction upheld by the Supreme Court.
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Case Digest (G.R. No. 179830)

Facts:

Election and Canvassing Responsibilities: On May 14, 2007, national and local elections were held under the supervision of the Commission on Elections (COMELEC). Lintang Bedol, as Chair of the Provincial Board of Canvassers (PBOC) for Maguindanao, was responsible for canvassing Certificates of Canvass (COCs) from 22 municipalities.

Failure to Attend Canvassing: Bedol failed to attend the scheduled canvassing of provincial COCs on May 22, 2007, and again on May 30, 2007, despite prior notice. He appeared only on May 25, 2007, to submit the provincial COC for Maguindanao but was questioned about alleged election fraud.

Loss of Election Documents: On June 11, 2007, Bedol appeared before the COMELEC’s Task Force Maguindanao and claimed that election paraphernalia were stolen on May 29, 2007. He failed to report the theft or submit a written explanation for his absences.

Media Statements and Defiance: On June 26, 2007, Bedol appeared in national media, flaunting a firearm and challenging the COMELEC to file a case against him.

Contempt Proceedings: On June 27, 2007, the COMELEC issued a Contempt Charge and Show Cause Order against Bedol for repeated absences, unlawful custody of election documents, and disrespectful conduct. Bedol was arrested on July 2, 2007, for failing to attend hearings.

COMELEC’s Ruling: On August 7, 2007, the COMELEC found Bedol guilty of contempt for his repeated failures to attend hearings, unlawful custody of documents, and disrespectful conduct. He was sentenced to six months imprisonment and a fine of P1,000. A motion for reconsideration was denied on August 31, 2007.

Issue:

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Ruling:

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Ratio:

Jurisdiction of the COMELEC: The COMELEC has broad powers, including quasi-judicial functions, to investigate election-related matters. The creation of Task Force Maguindanao was a legitimate exercise of this investigative power, and Bedol’s repeated absences and refusal to cooperate obstructed its functions. The COMELEC’s power to punish contempt is essential to its mandate to ensure free, honest, and credible elections.

Prejudgment and Due Process: The COMELEC did not pre-judge the case. Bedol was given multiple opportunities to explain his side and present evidence. His belated filings were considered, and the proceedings complied with due process requirements.

Substantial Evidence: The COMELEC’s findings were based on substantial evidence. Bedol’s repeated absences, unlawful custody of election documents, and defiant media statements were documented and established his contemptuous behavior. Newspaper clippings and his admissions during hearings were admissible evidence, and his refusal to present evidence implied an admission of guilt.


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