Title
Labay vs. People
Case
G.R. No. 241850
Decision Date
Apr 28, 2021
Petitioner convicted for double voter registration under RA 8189 after applying in Batangas and Calapan, despite canceling prior registration; SC upheld conviction.

Case Summary (G.R. No. 135222)

Charge and Information

Petitioner was charged by Information with violation of Section 10(j) in relation to Section 45(j) of RA 8189. The Information alleges that on December 26, 2001, while the voter registration process was continuing in Calapan City, petitioner, a registered voter of Barangay Malitam, Batangas City (VRR No. 22561463), willfully and unlawfully filed an application for registration at Precinct No. 109A, Barangay Maidlang 2, Calapan City (VRR No. 01119681), and declared under oath in that application that she was not a registered voter in any other precinct when, in truth, she remained a registered voter in Batangas City.

Prosecution Evidence and Factual Findings

The prosecution established: (1) petitioner’s registration in Batangas City on June 22, 1997 and her voting in the 1998 and 2001 elections there; (2) petitioner’s filing of a new registration application in COMELEC-Calapan City on December 26, 2001, during which she answered that she was not a registered voter elsewhere; (3) COMELEC-Calapan City approved that application relying on petitioner’s affirmative declaration; (4) petitioner later sought cancellation/transfer of her Batangas registration on July 2, 2002, and COMELEC-Batangas City issued a certification that the VRR was cancelled effective July 8, 2002; and (5) petitioner filed and won a barangay chairmanship election in July 2002, after which the present charges were among those filed by her opponent.

Petitioner’s Defense

Petitioner’s defensive assertions were that her Batangas registration had been cancelled by COMELEC-Batangas City on July 8, 2002; that she did not vote in Batangas City in the July 15, 2002 election or thereafter; and that she acted in good faith when applying for registration in Calapan City, having not voted twice in any single election. In essence, petitioner relied on the post-application cancellation and on absence of evidence of multiple voting to negate criminal intent or prejudice.

RTC Ruling

The RTC found petitioner guilty beyond reasonable doubt of violating Section 10(j) in relation to Sections 45(j) and 46 of RA 8189. The RTC sentenced petitioner to one (1) year imprisonment not subject to probation, imposed the accessory penalties of disqualification to hold public office and deprivation of the right of suffrage, and credited any preventive imprisonment. The RTC characterized double registration as malum prohibitum, concluding that petitioner’s intent was immaterial to the offense.

Court of Appeals Ruling and Subsequent Procedural History

The Court of Appeals, by Decision dated October 24, 2017, affirmed the RTC conviction. A Motion for Reconsideration filed by petitioner was denied by the CA in its Resolution dated September 6, 2018. Petitioner then filed the present Petition for Review on Certiorari under Rule 45 before the Supreme Court, which rendered the Decision dated April 28, 2021 affirming the CA in toto.

Issues Raised on Appeal

The petition presented three interrelated issues: (I) whether petitioner was convicted of the same offense charged in the Information; (II) whether petitioner was duly informed of the cause of the accusation of which she was convicted; and (III) whether Section 45(j) of RA 8189 is unconstitutional.

Rule 45 Jurisdictional Principles and Standard of Review

The Court reiterated that Rule 45 petitions are generally limited to questions of law; factual findings of the trial court, especially when affirmed by the CA, are ordinarily binding on the Supreme Court. The Court recalled the distinction between questions of law and questions of fact: a question of law may be resolved without reweighing the evidence, whereas a question of fact depends on evaluation of evidentiary probative value. The Court cited Torres v. People and other jurisprudence to emphasize that it is not a trier of facts and will not retry factual issues absent the recognized exceptions to Rule 45 (including grave abuse of discretion, findings grounded on speculation, manifestly mistaken inferences, misapprehension of facts, conflicting factual findings, overlooking undisputed relevant facts, or findings premised on absence of evidence contradicted by the record).

Analysis: Issues I and II — Sufficiency of the Information and Notice to Accused

The Court treated Issues I and II as essentially factual questions and, therefore, beyond the general ambit of a Rule 45 petition. Even assuming these issues could be entertained, the Court concluded that the Information was legally sufficient. The Court applied the controlling test for sufficiency of an Information: whether the crime is described in intelligible terms with such particularity as to apprise the accused with reasonable certainty of the offense charged. The Information in this case expressly identified petitioner’s prior registration (including VRR No. 22561463 and BATANGAS registration date), the subsequent application in Calapan (including VRR No. 01119681 and the December 26, 2001 date), and the false sworn statement that she was not a registered voter elsewhere. Given these specific allegations, the Court concluded that petitioner was adequately apprised of the charge of double registration (violation of Section 10(j) in relation to Sections 45(j) and 46) and thus received proper notice of the cause of accusation.

Analysis: Issue III — Constitutionality of Sec

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