G.R. No. 4089 - Pelayo vs. Lauron

Parties and Procedural History
Petitioners Edwin D. Rodriguez and Michael T. Defensor filed a petition for certiorari under Rule 64 seeking to annul COMELEC En Banc Resolution No. 10625 (14 November 2019) and Minute Resolution No. 20-0268-14 (17 June 2020).
Respondents are COMELEC, candidates Ma. Josefina G. Belmonte-Alimurung (mayor), Gian Carlo G. Sotto (vice mayor), Elizabeth A. Delarmente (representative), and TV host Wilfredo B. Revillame (alleged vote-buyer accomplice).

Underlying Complaint and COMELEC Proceedings
Petitioners’ Complaint Affidavit alleged that on 11 May 2019, during a Quezon City campaign rally, Revillame distributed cash to the audience “to induce” votes for Belmonte, Sotto, and Delarmente, as shown in uncorroborated video clips (Annex A) and stills (Annex B).
Respondents-candidates denied giving money; Revillame admitted giving small cash gifts but claimed charitable motives, not vote inducement. No witness affidavits authenticated the recordings or established chain of custody.
The COMELEC Law Department and Investigating Officer found (a) the rally and Revillame’s entertainment show were separate events, (b) petitioners offered no affidavits from witness-recipients as required by Section 28, RA 6646, and (c) videos/photographs without authentication were hearsay, thus no probable cause for vote-buying.
The COMELEC En Banc adopted these findings and dismissed the complaint (Resolution No. 10625); a motion for reconsideration was denied as a rehash (Minute Resolution No. 20-0268-14).

Whether the COMELEC En Banc committed grave abuse of discretion in dismissing the vote-buying complaint under Section 261(a)(1), Omnibus Election Code, on grounds that:
The evidence on record was sufficient to establish probable cause;
Respondents’ defenses raised matters for trial, not preliminary inquiry;
The resolutions were based on unwarranted assumptions and mischaracterizations of the events.