Case Summary (G.R. No. L-13403)
Factual Background
The parties were rival aspirants for the Nacionalista Party nomination for the fourth district of Pangasinan in the congressional election of November 12, 1957. On August 23, 1957 they executed a written agreement containing a pledge that each aspirant would respect the result of the party convention and would not run as a rebel or independent candidate if he or she lost. At the provincial convention held August 31, 1957, Saura was elected and proclaimed the party's official congressional candidate.
Defendant's Actions
Notwithstanding the pledge, Sindico filed her certificate of candidacy for the same congressional seat with the Commission on Elections on September 6, 1957, and she openly and actively campaigned for election as an independent or rebel candidate.
Plaintiff's Cause of Action
Saura commenced an action for damages against Sindico on October 5, 1957, alleging breach of the August 23, 1957 agreement by her filing of a certificate of candidacy and active campaign in violation of the pledge not to run after losing the party convention.
Trial Court Proceedings and Ruling
Upon motion of the defendant the Court of First Instance of Pangasinan dismissed the complaint by order dated November 19, 1957. The lower court held the agreement void on two grounds: first, that the subject matter, being a public office, was not within the commerce of man; and second, that the pledge unduly curtailed the free exercise of the elective franchise and was therefore contrary to public policy.
Issues on Appeal
The appeal presented legal questions whether the August 23, 1957 agreement and its pledge were valid and enforceable, and whether plaintiff could recover damages for defendant's conduct alleged to have breached that agreement.
Parties' Contentions on Appeal
Appellant urged the enforceability of the agreement and relied upon authorities such as Pendleton vs. Pace, 9 S. W. (2nd) 437, to support arrangements between opposing candidates under specified circumstances. Appellant also cited this Court's statement in Monsale vs. Nico, 83 Phil., 758; 46 Off. Gaz., 210 that a candidate may withdraw or annul his certificate of candidacy. Respondent maintained, as she had in the trial court, that the agreement was void because it attempted to transact rights pertaining to public office and to restrict the free exercise of the franchise.
Ruling of the Supreme Court
The Court affirmed the order of dismissal. It held the agreement to be a nullity and denied plaintiff's claim for damages arising from the defendant's candidacy and campaign.
Legal Basis and Reasoning
The Court reasoned that certain rights, including political rights such as the right to present one's candidacy and to be voted into public office, are excluded from the commerce of man and may not be bargained away for private consideration. These political rights serve the public interest and are subject only to the qualifications prescribed by constitutional and statutory provisions, which private parties cannot enlarge or diminish by contract. The Court cited Roberts vs. Cleveland, Secretary of State of the State of New Mexico, 48 NM 226, 149 P (2d) 120, 153 A.L.R. 635, 637-638 for the principle that a voter who possesses the qualifications required by law has the right to be a candidate and that the statute, not private agreement, governs party candidacy and general election participation. The Court observed that common-law authorities and annotations condemned agreements made in consideration of the withdrawal of candidates as contrary to public policy. The appellate opinion found Pendleton vs. Pace inapplicable because that case upheld an agreement to resubmit nomination to electors following a co
...continue readingCase Syllabus (G.R. No. L-13403)
Parties and Procedural Posture
- Ramon E. Saura filed a complaint for damages against Estela P. Sindico on October 5, 1957.
- The action arose from a political contest for the Nacionalista Party nomination in the fourth district of Pangasinan for the November 12, 1957 congressional elections.
- The Court of First Instance of Pangasinan dismissed the complaint by order dated November 19, 1957.
- The plaintiff appealed to the Court, and the appeal raised issues of law from the lower court's order.
Key Factual Allegations
- The parties competed for the Nacionalista Party nomination for the same congressional seat in Pangasinan.
- The parties executed a written agreement dated August 23, 1957, containing a pledge that no losing aspirant would run as a rebel or independent candidate.
- In the provincial convention held August 31, 1957, Saura was elected and proclaimed the Party's official congressional candidate.
- Sindico nevertheless filed her certificate of candidacy on September 6, 1957, and openly and actively campaigned for election.
- Saura alleged breach of the August 23, 1957 agreement and sought recovery of damages.
Agreement Terms
- The parties entered into a written agreement dated August 23, 1957, containing a stipulation that "Each aspirant shall respect the result of the aforesaid convention, i.e., no one of us shall either run as a rebel or independent candidate after losing in said convention."
- The agreement thus consisted of a private pledge by aspirants not to pursue candidacy independent of the party after losing the convention.
Lower Court Ruling
- The trial court held the agreement null and void and dismissed the complaint on November 19, 1957.
- The lower court reasoned that the subject matter of the contract, being a public office, was not within the commerce of man.
- The lower court further held that the pledge curtailed the free exercise of the elective franchise and was therefore against public policy.
Issues Presented
- Whether a private agreement by political aspirants not to run as independent or rebel candidates after losing a party convention is valid and enforceable.
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