Case Summary (G.R. No. 255509)
Factual Allegations
Petitioners alleged that during a campaign rally on May 11, 2019, Revillame distributed cash to attendees while Belmonte, Sotto, and Delarmente were onstage, thereby inducing votes in violation of Sec. 261(a)(1). Petitioners submitted uncorroborated video clips and still photographs as evidence.
Procedural History
Petitioners filed a verified Complaint Affidavit with supporting media before the COMELEC Law Department. The Investigating Officer and the Law Department recommended dismissal for lack of probable cause. The COMELEC En Banc adopted these recommendations in Resolution No. 10625 and denied reconsideration in Minute Resolution No. 20-0268-14.
COMELEC Law Department Findings
- Petitioners failed to present affidavits from voters confirming receipt of cash for voting.
- Video and photographs lacked authentication and chain of custody.
- Belmonte, Sotto, and Delarmente did not give cash; Revillame’s distributions were personal and not tied to vote inducement.
- No mens rea to induce votes was established.
COMELEC En Banc Resolutions
- Dismissed the complaint for insufficiency of evidence and lack of probable cause.
- Held the campaign rally and Revillame’s entertainment show as distinct events.
- Affirmed that respondents did not conspire or manifest intent to buy votes.
Grounds for Supreme Court Review
Petitioners argued that the COMELEC En Banc:
- Erred in finding no probable cause despite submitted evidence.
- Improperly resolved factual issues better suited for trial.
- Based resolutions on unwarranted assumptions.
The Office of the Solicitor General countered that the entertainment show formed part of the miting de avance and that Revillame’s acts, in respondents’ presence, evidenced vote-buying.
Constitutional and Statutory Framework
- The 1987 Constitution vests COMELEC with exclusive power to investigate and prosecute election offenses.
- Sec. 261(a)(1) requires proof that a person gave or promised money or anything of value with intent to induce votes.
- Sec. 28, RA 6646 mandates that complaints be supported by affidavits of complaining witnesses; failure to do so justifies dismissal.
Deference to COMELEC Findings
The Supreme Court emphasized its limited power to review COMELEC’s factual determinations absent grave abuse of discretion, arbitrariness, or error of law.
Insufficiency of Evidence
- Petitioners offered no direct testimony from recipients confirming inducement to vote.
- Uncorroborated video and photographs carry weak evidentiary value.
- Self-serving statements without supporting affidavits cannot establish probable cause.
Importance of Supporting Affidavits and Witness Testimony
- Section 28 requires affidavits from complaining witnesses to trigger investigation.
- The immunity provisions encourage vote-sellers to testify but were unused by petitioners.
- Respondents secured affidavits from actual recipients, showing Revillame personally made distri
Case Syllabus (G.R. No. 255509)
Procedural Posture
- Petitioners Edwin D. Rodriguez and Michael T. Defensor filed a Petition for Certiorari under Rule 64 of the Rules of Court.
- They sought to annul and set aside COMELEC En Banc Resolution No. 10625 (14 November 2019) and Minute Resolution No. 20-0268-14 (17 June 2020) in E.O. Case No. 19-199.
- The subject resolutions dismissed petitioners’ Complaint Affidavit for violation of Section 261(a)(1) of the Omnibus Election Code (vote-buying) for lack of probable cause.
Antecedents
- Petitioners, registered voters of Quezon City, filed a Complaint Affidavit against respondents, alleging vote-buying at a May 11, 2019 campaign rally.
- Respondents Belmonte, Sotto, and Delarmente were candidates for Mayor, Vice-Mayor, and First District Representative of Quezon City in the May 2019 elections.
- Respondent Revillame, a television personality, performed an entertainment show immediately following the rally.
Allegations in Complaint Affidavit
- During the rally along Roosevelt Avenue, Revillame purportedly gave cash to the crowd while onstage with Belmonte, Sotto, and Delarmente.
- After distributing money, Revillame allegedly endorsed the three candidates for public office.
- Petitioners attached a DVD of the live-streamed video (Annex “A”) and still photos (Annexes “B,” “B-1” to “B-19”) as evidence.
- Petitioners asserted these acts constituted vote-buying under Sec. 261(a)(1) of BP 881.
Defenses of Respondents
- All respondents denied vote-buying and asserted no probable cause:
- Belmonte, Sotto, and Delarmente denied distributing money and characterized the entertainment show as a separate event.
- Revillame admitted giving small cash amounts but maintained they were personal gifts fo