G.R. No. 158734 - Albana vs. Belo

The petitioners filed a petition for review under Rule 45 of the Rules of Court, seeking to annul the COMELEC En Banc Resolution dated February 28, 2003, and the subsequent Resolution dated June 3, 2003.
The COMELEC found probable cause against the petitioners for election offenses, specifically violations of Section 261 (a) and (e) of the Omnibus Election Code, and directed the filing of an Information in a competent court.
The case is related to a previous decision by the Supreme Court in Alba a v. Commission on Elections, which involved the same facts and issues.

The petitioners were elected as municipal officials in Panitan, Capiz, during the May 14, 2001 elections.
Following their proclamation on May 18, 2001, private respondents filed a complaint against them, alleging acts of terrorism and vote-buying.
The COMELEC Law Department found a prima facie case and recommended filing charges against the petitioners, leading to the issuance of the February 28, 2003 resolution.

The February 28, 2003 resolution directed the filing of Information against the petitioners and the docketing of the electoral aspect of the complaint as a disqualification case.
The petitioners filed a motion for reconsideration, which was denied on June 3, 2003, for lack of merit and being filed out of time.

On October 21, 2003, the COMELEC First Division annulled the petitioners' proclamation, citing violations of the Omnibus Election Code.
The petitioners' subsequent motion for reconsideration was denied, affirming their disqualification and the nullification of their election.

The petitioners argued that the COMELEC erred in finding probable cause based on dubious affidavits and insufficient evidence.
They contended that their constitutional rights to notice and due process were violated, as the issue of disqualification was not raised during the proceedings.
The petitioners also claimed that the COMELEC's resolution did not conform to constitutional requirements and that the period for filing a motion for reconsideration was misapplied.

The respondents maintained that the COMELEC's finding of probable cause was supported by substantial evidence, including affidavits detailing acts of intimidation and vote-buying.
They argued that the issue of disqualification was indeed raised in the proceedings and that the COMELEC's resolution provided adequate factual and legal bases for its findings.

The Supreme Court reiterated that the determination of probable cause rests within the COMELEC's discretion, and it is not the role of the Court to interfere unless there is a clear showing of grave abuse of discretion.
Probable cause is defined as a reasonable ground for presuming that a matter is well-founded, and it does not require absolute certainty or a full display of evidence.

The Court found that the COMELEC's determination of probable cause was based on sufficient evidence, including affidavits that indicated widespread vote-buying and intimidation during the elections.
The Court emphasized that the allegations of terrorism and vote-buying constituted valid grounds for election offenses under the Omnibus Electi...continue reading