Case Digest (G.R. No. 115245) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Juanito C. Pilar v. Commission on Elections (G.R. No. 115245, July 11, 1995), petitioner Juanito C. Pilar filed his Certificate of Candidacy on March 22, 1992 for the position of Member of the Sangguniang Panlalawigan of Isabela. He withdrew his candidacy three days later, on March 25, 1992. Despite the withdrawal, the Commission on Elections (COMELEC) imposed administrative fines of Ten Thousand Pesos (P10,000.00) on November 3, 1993 (M.R. No. 93-2654) and February 13, 1994 (M.R. No. 94-0065) for his failure to file the statement of contributions and expenditures (SC&E) required under Section 14 of Republic Act No. 7166. After denial of his motions for reconsideration on February 24, 1994 and the COMELEC En Banc Resolution dated April 28, 1994 in UND No. 94-040, Pilar elevated the matter to the Supreme Court via a Petition for Certiorari under Rule 65 of the Revised Rules of Court. Petitioner contended he was a “non-candidate” upon withdrawal and thus Case Digest (G.R. No. 115245) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Filing and withdrawal of candidacy
- March 22, 1992: Petitioner Juanito C. Pilar filed his certificate of candidacy for member of the Sangguniang Panlalawigan, Province of Isabela.
- March 25, 1992: Petitioner withdrew his certificate of candidacy.
- Administrative proceedings before COMELEC
- M.R. Nos. 93-2654 (Nov. 3, 1993) and 94-0065 (Feb. 13, 1994): COMELEC imposed an administrative fine of ₱10,000.00 each for failure to file statement of contributions and expenditures.
- M.R. No. 94-0594 (Feb. 24, 1994): COMELEC denied petitioner’s motion for reconsideration and deemed the fines final.
- En Banc, UND No. 94-040 (Apr. 28, 1994): COMELEC denied petitioner’s petition, prompting this Rule 65 certiorari to the Supreme Court.
- Applicable statutory and regulatory provisions
- Section 14, R.A. No. 7166: Requires every candidate and political party treasurer to file, within 30 days after election, full, true, and itemized statements of contributions and expenditures; prescribes fines of ₱1,000–₱30,000 for failure to file and higher fines plus perpetual disqualification for repeat offenses; prohibits entry into office without filing.
- COMELEC Resolution No. 2348 (Jan. 13, 1992): Implements R.A. 7166 by requiring written reminders to candidates (Sec. 13) and reiterating mandatory filing with penalties (Sec. 17).
Issues:
- Whether a person who withdraws his certificate of candidacy remains a “candidate” obligated to file a statement of contributions and expenditures under Section 14, R.A. No. 7166 and COMELEC Resolution No. 2348.
- Whether failure to file the statement by a withdrawn candidate constitutes an administrative offense punishable by fine and prohibition from office.
- Whether the COMELEC En Banc correctly imposed and affirmed the administrative fine on petitioner.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)