Case Summary (G.R. No. 261107)

Case Overview

• Case Title: Ana Liza Arriola Peralta vs. Commission on Elections
• Date: January 30, 2024
• Nature of Petition: Petition for Certiorari challenging COMELEC Resolutions regarding election overspending.

Background

• Petitioner: Ana Liza A. Peralta, candidate for Mayor of San Marcelino, Zambales in the 2010 National and Local Elections.
• Respondent: Commission on Elections (COMELEC)
• Legal Issue: Allegations of overspending on campaign expenditures beyond the legal limit set by the Omnibus Election Code (OEC) as amended by Republic Act No. 7166.

Relevant Legal Provisions

Omnibus Election Code (OEC)

• Section 100: Limits expenditure for election campaigns.

  • Maximum allowable expenditure = PHP 3.00 per registered voter.
  • For San Marcelino's 20,301 registered voters, total limit = PHP 60,903.00.

• Section 262: Defines election offenses including overspending.

Timeline of Events

• June 7, 2010: Petitioner submits Statement of Contributions and Expenditures (SOCE).
• October 1, 2014: COMELEC requests an explanation for alleged overspending.
• May 9, 2015: COMELEC files a motu proprio complaint against petitioner.
• August 8, 2018: Resolution finding probable cause for trial issued.
• July 14, 2021: Motion for reconsideration denied.

Key Findings

Allegations of Overspending

• Petitioner reported expenditures totaling PHP 285,500.00.
• Allegations state this exceeded the legal limit by PHP 224,597.00 (368.77%).

Petitioner’s Defense

• Claimed errors in SOCE due to her secretary's misreporting.
• Submitted affidavits from contributors correcting discrepancies in reported contributions.

COMELEC's Rulings

• Resolution No. 18-0656 (August 8, 2018): Found probable cause to charge petitioner with overspending.
• Resolution No. 21-0472-57 (July 14, 2021): Denied petitioner's motion for reconsideration.

Supreme Court's Ruling

Right to Speedy Disposition

• The Court ruled that there was inordinate delay in the preliminary investigation, violating the petitioner’s constitutional right to a speedy disposition of cases.
• The Court followed guidelines from previous cases (e.g., Cagang v. Sandiganbayan) regarding delays:
  • Determination of Delay: Evaluates length, reasons, and prejudice caused to the accused.
  • Burden of Proof: Shifts to prosecution to justify delays beyond prescribed periods.

Conclusion

• Decision: Petition granted; COMELEC resolutions nullified, and the complaint against Peralta dismissed.
• Implications: Reinforces the necessity for timely action in election-related cases to prevent undue prejudice against candidates.

Key Takeaways

• The decision emphasizes the importance of a timely preliminary investigation in election offenses.
• Acknowledges that delays can undermine the integrity of the electoral process and the rights of candidates.
• Clarifies that the responsibility

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Case Syllabus (G.R. No. 261107)

Background of the Case

• The petition involves a challenge against Resolution No. 18-0656 dated August 8, 2018, and Resolution No. 21-0472-57 dated July 14, 2021, issued by the Commission on Elections (COMELEC) En Banc in E.O. Case No. 15-954.
• Ana Liza A. Peralta, the petitioner, was found to have exceeded the allowable campaign expenditure during the May 10, 2010 National and Local Elections (2010 NLE) for the position of Mayor in San Marcelino, Zambales.
• The total registered voters in San Marcelino were 20,301, which set her maximum allowable expenditure at PHP 60,903.00 (PHP 3.00 per voter).
• Petitioner declared expenditures amounting to PHP 285,500.00 in her Statement of Contributions & Expenditures (SOCE) submitted to COMELEC on June 7, 2010.

Events Leading to the Complaint

• A letter from Atty. Ferdinand T. Rafanan of the COMELEC on October 1, 2014, informed Peralta of the overspending and requested a written explanation to avoid charges.
• In her response dated March 2, 2015, she submitted affidavits from her contributors explaining discrepancies in the reported contributions.
• Despite her explanations, the COMELEC filed a motu proprio complaint against her for election overspending on May 9, 2015.

The Complaint and Preliminary Investigation

• The complaint alleged that petitioner exceeded the expenditure limit by PHP 224,597.00 (368.77% over the lim

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