G.R. No. L-52390 - Santos vs. Commission on Elections

Manuel I. Santos, the petitioner, filed a petition contesting the Commission on Elections (COMELEC) resolution disqualifying him as the Nacionalista Party (NP) candidate for Mayor of Taytay, Rizal in the January 1980 local elections.
The disqualification was based on allegations of “political turncoatism” whereby Santos was accused of changing his political party affiliation—from being a member and active participant in the Kilusang Bagong Lipunan (KBL) to later seeking nomination under the NP.

The COMELEC resolution dated January 19, 1980 found that Santos had submitted a letter of resignation from the KBL on January 2, 1980.
The resolution noted that despite his resignation, evidence showed Santos’ active involvement with the KBL, including serving as a member of its municipal committee.
COMELEC held that his active participation and subsequent switch to the NP violated constitutional provisions that prohibit changing political party affiliation within six months preceding or following an election, as well as Presidential Decree No. 1661 concerning “guest candidates.”
The factual record demonstrated a scenario similar to the earlier case of Evasco vs. COMELEC, where a candidate’s participation in a distinct political party (the KBL) led to his disqualification for political turncoatism.

Santos argued that he had always been a loyal member of the NP and that his so-called change in affiliation was misinterpreted; he contended that the KBL was merely an umbrella organization rather than a distinct political party.
His argument was not unequivocally asserted in his Answer to the disqualification petition, and COMELEC rejected his contention based on the evidentiary record, emphasizing that the act of “resigning” was indicative of his full participation in the KBL as a bona fide political party.
Additional reference was made to earlier cases and resolutions establishing the standing of the KBL as a separate and accredited political party, which further bolstered the COMELEC’s position.

A dissenting opinion by Justice Teehankee criticized the majority ruling, arguing that Santos’ resignation from the KBL clearly demonstrated his lasting loyalty to the NP.
The dissent emphasized that the KBL’s transformation into a political party should have been interpreted differently and that any pre-election disqualification issues should have been resolved via appropriate election protests or quo warranto proceedings rather than pre-proclamation remedies.

Whether the COMELEC resolution disqualifying petitioner Santos for political turncoatism is supported by substantial evidence.

The central issue was the sufficiency of evidence that Santos actively participated in the KBL and then sought nomination under the NP.
Whether such participation, evidenced by his membership and role in the KBL’s municipal committee, amounted to a violation of the constitutional prohibition against changing political affiliation within the prescribed period.

Whether the evidence evaluated by the COMELEC meets the threshold of “substantial evidence” required for upholding its ruling.
Whether the COMELEC’s determination regarding the KBL as an independent political party—as distinct from the NP—is within its exclusive power and free from reversible error or grave abuse of discretion.

Whether Santos’ claim that the regulations against turncoatism, particularly PD No. 1661, should not apply to him because of the short notice before the elections or that the rule has ex post facto effect.
Whether the petitioner’s due process rights were infringed by the timely enforced resolution of disqualification despite his participation in a pre-proclamation grace measure.