G.R. No. 261107 - Ana Liza Arriola Peralta vs. Commission on Elections, represented by the Campaign Fice Unit

Ana Liza A. Peralta, the petitioner, ran for Mayor of San Marcelino, Zambales, in the May 10, 2010 National and Local Elections (NLE).
The municipality had 20,301 registered voters, allowing a maximum campaign expenditure of PHP 60,903.00 (PHP 3.00 per voter).
Peralta reported expenditures of PHP 285,500.00 in her Statement of Contributions and Expenditures (SOCE) submitted to the Commission on Elections (COMELEC).
Atty. Ferdinand T. Rafanan of the COMELEC informed Peralta of her overspending and requested an explanation to avoid charges.

In her response, Peralta provided affidavits from contributors clarifying discrepancies in reported contributions.
Contributors claimed errors in the amounts and descriptions of their contributions, attributing these to misunderstandings or mistakes.
Peralta cited her limited mobility due to a hip surgery and the geographical distance from her contributors as factors affecting her ability to verify contributions.

Despite Peralta's explanations, the COMELEC filed a complaint against her for election overspending on May 9, 2015.
The complaint detailed the alleged overspending and the discrepancies in her SOCE.
A preliminary investigation was initiated, and Peralta was summoned to submit a counter-affidavit.

Peralta denied the allegations, asserting that the SOCE contained errors due to her secretary's misreporting.
She argued that her actual expenditures were only PHP 51,500.00, not the reported PHP 285,500.00.
The secretary admitted to errors in categorizing contributions and acknowledged her limited knowledge of campaign finance laws.

In Resolution No. 18-0656, the COMELEC found probable cause to charge Peralta with election overspending.
The COMELEC emphasized that Peralta, as a former councilor and lawyer, should have been aware of campaign finance laws.
Peralta's motion for reconsideration was denied in Resolution No. 21-0472-57.

Peralta filed a petition for certiorari, alleging grave abuse of discretion by the COMELEC.
She claimed inordinate delay in the preliminary investigation, lack of evidence for the charges, and absence of all elements constituting the offense.

The Court found that the COMELEC took an excessive amount of time to conduct the preliminary investigation, violating Peralta's right to a speedy disposition of her case.
The timeline showed significant delays, with the complaint filed in May 2015 and t...continue reading