Case Digest (G.R. No. 176492)
Facts:
This case involves Ma. Zarah Rose De Guzman-Lara (petitioner) and Manuel N. Mamba (respondent), candidates for Governor of Cagayan Province during the May 2022 National and Local Elections. Mamba was the incumbent governor who was proclaimed the winner early morning on May 11, 2022, after garnering the highest votes. On May 10, 2022, Lara filed a petition for disqualification against Mamba with the Commission on Elections (COMELEC) citing massive vote-buying and unlawful public fund disbursement during the campaign period, violating Section 68 of the Omnibus Election Code (OEC). The petition was filed via electronic mail at 6:21 PM, just hours before Mamba’s proclamation at 1:39 AM on May 11. The COMELEC Second Division found merit in the petition and disqualified Mamba on December 14, 2022, for violation of Section 261(v) of the OEC concerning unlawful disbursement of public funds within the 45-day prohibitory period before the election. However, the COMELEC En Banc later dismiCase Digest (G.R. No. 176492)
Facts:
- Parties and Context
- Ma. Zarah Rose De Guzman-Lara (Lara) and Manuel N. Mamba (Mamba) were candidates for Governor of Cagayan Province during the May 2022 National and Local Elections.
- Mamba was the incumbent governor, elected in 2019.
- Petition for Disqualification
- Lara filed on May 10, 2022, a Petition for Disqualification against Mamba alleging massive vote-buying and unlawful disbursement of public funds contrary to Section 68 of the Omnibus Election Code (OEC).
- Lara sought an order to suspend and hold Mamba’s proclamation pending resolution of the petition.
- Lara alleged Mamba used provincial government funds to distribute cash assistance programs (e.g., "No Barangay Left Behind") during the campaign period (March 25 to May 8, 2022).
- Proclamation and Initial Rulings
- Mamba was proclaimed as governor on May 11, 2022, by the Provincial Board of Canvassers.
- On December 14, 2022, the COMELEC Second Division granted Lara’s petition, disqualifying Mamba based primarily on violation of Section 261(v) of the OEC for unauthorized disbursement of public funds within 45 days before the election.
- COMELEC En Banc Resolution
- Mamba filed a motion for reconsideration challenging the sufficiency of evidence.
- On March 6, 2023, COMELEC En Banc dismissed Lara’s petition for disqualification citing lack of jurisdiction because the petition was filed after Mamba’s proclamation.
- COMELEC applied its Resolution No. 10673 which deemed electronic filings after 5:00 PM as filed the next working day, thus the petition was considered filed on May 11, 8:00 AM, after the proclamation at 1:39 AM.
- Petition for Certiorari Before the Supreme Court
- Lara filed a Petition for Certiorari contesting the dismissal and asserting timely filing since the petition was electronically sent before proclamation.
- She argued for liberal interpretation of procedural rules considering the stakes in election cases.
- COMELEC and Mamba maintained that jurisdiction was divested after proclamation and the petition was untimely.
Issues:
- Whether the COMELEC En Banc gravely abused its discretion by dismissing the Petition for Disqualification for lack of jurisdiction on the ground of late filing.
- Whether the COMELEC should have affirmed the Second Division’s December 14, 2022 resolution disqualifying Mamba.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)