Case Summary (G.R. No. 137266)
Allegations of Vote Buying and Facts of the Case
The complaint accused the respondents of conspiration to conduct an all-expense-paid event for public school teachers at Tayabas Bay Beach Resort, Quezon, which included free transportation, food, and political advertising materials endorsing Benjamin "Benhur" Abalos, Jr. The teachers were allegedly promised additional benefits including a "hazard" pay of P1,000 and increased allowances from P1,500 to P2,000. These promises were allegedly made with the intent to influence the teachers and other attendees to vote for the respondent candidate. The complainants argued that such acts violated the anti-vote-buying provisions of the Omnibus Election Code.
Proceedings Before the COMELEC and Its Findings
The Director of the Law Department of COMELEC conducted a preliminary investigation and recommended dismissal of the complaint due to insufficiency of evidence, which the COMELEC En Banc adopted in Resolution No. 98-3208 dated December 1, 1998. The COMELEC found that the petitioners’ evidence were mainly self-serving statements and uncorroborated audio-visual recordings and photographs. The respondents’ evidence was deemed more credible and probative. The ruling emphasized that the complainants, bearing the burden of proof in this criminal matter, failed to adequately substantiate their allegations.
Petitioners’ Failure to Exhaust Administrative Remedies
The petitioners filed a certiorari petition with the Supreme Court without first filing a motion for reconsideration with the COMELEC En Banc, which is a mandatory procedural step under the 1993 COMELEC Rules of Procedure, specifically Section 1, Rule 13. Although motions for reconsideration of en banc resolutions are generally disallowed, an exception exists for election offense cases such as this. The petitioners gave no plausible justification for their circumventing of this requirement, referring only to a broad claim that filing such a motion would cause unnecessary delay.
Supreme Court's Rationale on Procedural Requirements
The Supreme Court underscored the importance of the procedural rule mandating motions for reconsideration as a mechanism for the COMELEC to correct any errors internally before judicial intervention. This mechanism aims to ensure orderly, just, expeditious, and inexpensive disposition of election-related cases. Failure to comply with this procedure renders the petition premature. The Court held that a Rule 65 petition for certiorari is appropriate only where there is no plain, speedy, and adequate remedy, which was not the case here due to the absence of a motion for reconsideration.
Substantive Considerations on the Insufficiency of Evidence
Beyond the procedural infirmity, the Supreme Court affirmed the COMELEC’s factual findings noting that
...continue readingCase Syllabus (G.R. No. 137266)
Background and Nature of the Case
- This case involves a petition for certiorari filed under Rule 65 of the 1997 Rules of Civil Procedure, as amended, challenging Resolution No. 98-3208 issued by the Commission on Elections (COMELEC) En Banc on December 1, 1998.
- The petitioners are Antonio M. Bernardo, Ernesto A. Domingo, Jr., and Jesus C. Cruz.
- The respondents include Benjamin S. Abalos, Sr., Benjamin "Benhur" D. Abalos, Jr., Dr. Eden C. Diaz, Romeo F. Zapanta, Arcadio S. De Vera, and the COMELEC.
- The petition seeks the nullification of the COMELEC resolution that dismissed the vote-buying complaint filed against respondents.
Facts and Alleged Offenses
- On April 21, 1998, the petitioners filed a criminal complaint for vote-buying against the respondents before the COMELEC based on alleged violations of Section 261, paragraphs (a), (b), and (j) of the Omnibus Election Code (OEC), in relation to Section 28 of Republic Act 6646 and Section 68 of the OEC.
- The complaint (E.O. Case No. 98-110) alleged that on April 14, 1998:
- Mandaluyong City Mayor Benjamin S. Abalos, Sr., and his son Benjamin "Benhur" Abalos, Jr., along with other respondents, sponsored an all-expense-paid affair for Mandaluyong City public school teachers who are registered voters.
- The event was held at Tayabas Bay Beach Resort in Quezon Province and was attended by numerous public school teachers, principals, supervisors, and officers of the Mandaluyong Federation of Public School Teachers.
- The event featured political jingle music promoting Benjamin "Benhur" Abalos, Jr., and participants wore T-shirts printing his name.
- Mayor Abalos, Sr. gave a speech promising teachers an increase in hazard pay and allowances shortly before the 1998 elections, which was alleged to be an inducement to vote for his son.
- These acts were argued to constitute vote-buying and vote-selling prohibited under the law.
Proceedings and Investigations
- The Director of the Law Department of the COMELEC conducted a preliminary investigation.
- Respondents submitted counter-affidavits requesting dismissal of the complaint.
- On November 26, 1998, the Director recommended dismissal due to insufficiency of evidence.
- On December 1, 1998, the COMELEC En Banc adopted this recommendation, dismissing the complai