Title
Reyes vs. Commission on Elections
Case
G.R. No. L-13069
Decision Date
May 28, 1958
Jovencio A. Reyes' candidacy for Congress was challenged as filed in bad faith due to lack of campaign activity. The Supreme Court ruled COMELEC abused its discretion, emphasizing its ministerial duty to accept candidacies meeting legal qualifications, not subjective impressions.
certificate of candidacy
jurisdiction
campaign activities

Case Summary (G.R. No. L-13069)

Factual Background

After petitioner filed his certificate of candidacy on August 20, 1957, the Commission informed him that it would give his certificate due course. On September 22, 1957, Godofredo S. Reyes moved to cancel petitioner’s certificate on the allegation of bad faith, which triggered an investigation by the Commission “in accordance with the established practice” for such cases.

The Commission concluded that petitioner’s certificate was filed in bad faith based on several factual findings: petitioner purportedly did not campaign, had no substantial campaign materials except a single small poster on an acacia tree along the road leading to Santiago, Ilocos Sur; there was allegedly no political activity in any of the towns and municipal districts forming the second congressional district of Ilocos Sur, except for letters mailed from Manila seeking permits to hold political meetings in certain towns; petitioner was allegedly unable or unwilling to hold political meetings even after the filing of his certificate of candidacy up to October 27, 1957; he allegedly did not conduct house-to-house campaigning; and witnesses allegedly stated that they had not seen him for a long time because he resided in Quezon City.

When petitioner’s petition reached the Supreme Court, the Court granted a preliminary injunction ordering the Commission to give due course to the certificate. During subsequent hearing on November 9, petitioner personally appeared, argued his case as a lawyer, and the Court had an opportunity to see and inquire into his qualifications, which the Court found to be complete.

The Parties’ Contentions

Petitioner contended that the Commission’s refusal to give due course to his certificate of candidacy constituted both (a) an excess of the Commission’s jurisdiction and (b) an abuse of discretion. The Court framed the core of petitioner’s position as follows: the refusal was not due to any disqualification, lack of competence, or absence of requisite qualifications prescribed by law, but instead rested on the Commission’s belief that petitioner had not shown sufficient interest in campaigning.

The Commission’s position was that petitioner’s alleged lack of campaigning—failure to hold meetings and failure to distribute sufficient posters—reflected bad faith and justified the withholding of due course. Petitioner, however, argued that such a conclusion improperly converted campaign practices into a jurisdictional requirement for due course even when qualifications and lack of statutory disqualifications were established.

The Court’s Evaluation of “Bad Faith” and Good Faith Presumptions

The Supreme Court rejected the Commission’s conclusion of bad faith. The Court stated that good faith is always to be presumed. It reasoned that a candidate may genuinely believe that the mere announcement of candidacy through the filing of the certificate is sufficient. It also held that the failure to hold campaign meetings or distribute posters may be motivated by a desire not to stoop to the usual forms of winning votes, a choice that could be impelled by ethical principles and by a wish to give the electorate freedom of choice without resorting to common campaign methods.

The Court further recognized that a candidate may consider it beneath his dignity to engage in ordinary campaign practices and that such sentiment does not contradict good faith. Accordingly, the Court held that the Commission committed an abuse of discretion when it inferred bad faith solely from petitioner’s refusal to follow “common and ordinary” campaigning practices.

Limits on the Commission on Elections’ Power to Withhold Due Course

Beyond the evidentiary weakness of the bad faith finding, the Court held that the Commission went beyond its powers. It characterized the Commission’s action as an assumption of the “dangerous prerogative” of determining, based on its own belief or impressions, whether due course should be granted to a candidacy, even when the candidate possesses all legal qualifications and none of the disqualifications set forth by law.

The Court relied on prior doctrine explaining that Sections 36 and 37 of the Revised Election Code did not confer upon the Commission any discretion to refuse due course. The Court emphasized that, under these provisions, the Commission had an admittedly ministerial duty to receive the certificate and to give it due course; otherwise, the act of receiving the certificate would be meaningless. It also stressed that the Constitution fixes qualifications for the President, and thus those who meet constitutional qualifications are deemed legally fit to aspire and run, provided they comply with statutory procedural filing requirements. The Court added that the Commission’s decision-making authority was limited to purely “administrative questions” and had no authority to decide matters involving the right to vote, including passing upon the legality of individual votes.

In the same doctrinal vein, the Court quoted the reasoning from Abcede vs. Hon. Domingo Imperial, et al., where the Court had explained that the Commission could not determine who among qualified and procedurally compliant persons should enjoy the benefits intended by law. The Supreme Court treated tha

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