Case Summary (G.R. No. 241850)
Procedural Background
Labay was found guilty of violating Section 10(j) in relation to Sections 45(j) and 46 of RA 8189. Her conviction by the Regional Trial Court (RTC) on December 2, 2014, was subsequently affirmed by the Court of Appeals (CA) on October 24, 2017, and again in a Resolution dated September 6, 2018, following her motion for reconsideration.
Allegations and Sequence of Events
The Information filed against Labay alleged that on December 26, 2001, she willfully and unlawfully registered as a voter in Calapan City while still being a registered voter in Batangas City. This was compounded by her declaration, under oath, that she did not have any other voter registration. The prosecution established that her voter registration in Batangas City was dated June 22, 1997, and she had voted in the 1998 and 2001 elections prior to seeking new registration in Calapan City.
Defense Claims
In her defense, Labay argued that her registration in Batangas City had been canceled by the election officials prior to her application in Calapan City. She maintained that she acted in good faith under the belief that she was no longer registered to vote in Batangas and claimed she did not cast votes in more than one city.
Ruling of the Lower Court
The RTC sentenced Labay to one year of imprisonment, disqualified her from holding public office, and deprived her of the right to vote. The court characterized the offense as malum prohibitum, meaning the omission of intent constituted a violation of the law irrespective of Labay's understanding of her actions.
Court of Appeals' Affirmation
The CA upheld the RTC's findings, ruling that Labay's actions constituted a clear violation of election laws. Labay's appeal was dismissed, affirming her conviction and the penalties imposed by the RTC.
Issues Presented
The following legal issues were identified for resolution:
- Whether Labay was convicted of the same offense as that charged in the Information.
- Whether she was adequately informed of the charges against her.
- Whether Section 45(j) of RA 8189 was unconstitutional.
Legal Principles and Rulings
The Supreme Court held that the petition lacked merit, reiterating that its jurisdiction in a Rule 45 petition is limited to questions of law and that factual matters are beyond its scope. The Court emphasized that the information sufficiently detailed the offense, providing adequate notice to Labay regarding the charges of double registration.
Constitutionality of the Statute
The Court dismissed challenges regarding the constitutionality of Section 45(j) of RA 8189, asserting that the statute i
...continue readingCase Syllabus (G.R. No. 241850)
Case Overview
- This case involves a Petition for Review on Certiorari under Rule 45, filed by Honorata A. Labay (petitioner) against the People of the Philippines (respondent).
- The petition challenges the Decision dated October 24, 2017, and the Resolution dated September 6, 2018, of the Court of Appeals (CA) in CA G.R. CR No. 38793.
- The CA affirmed the Decision dated December 2, 2014, of Branch 39, Regional Trial Court (RTC), Calapan City, Oriental Mindoro, which found Labay guilty beyond reasonable doubt of violating Section 10(j), in relation to Sections 45(j) and 46 of Republic Act No. 8189.
Antecedents of the Case
- Petitioner Labay was charged with violating Section 10(j) in relation to Section 45(j) of RA 8189 through an Information dated December 26, 2001.
- The Information stated that Labay, a registered voter in Barangay Malitam, Batangas City, unlawfully filed an application for registration in Calapan City, declaring under oath that she was not a registered voter elsewhere.
- The prosecution established that Labay registered in Batangas City on June 22, 1997, and voted in the 1998 and 2001 elections.
- On December 26, 2001, she applied for new registration in Calapan City, falsely asserting she was not registered elsewhere.
Proceedings and Key Dates
- Labay requested the cancellation of her Batangas City registration on July 2, 2002, which was certified as canceled on July 18, 2002.
- She successfully filed a certificate of candidacy for a barangay chairman position in Calapan City during the July 15, 2002 elections.
- Following her election