G.R. No. 262622 - Teves vs. Commission on Elections

Case Summary (G.R. No. 262622)

Factual Background

On October 7, 2021, Roel R. Degamo filed a Certificate of Candidacy for Governor of Negros Oriental under the Nacionalista Party. On October 8, 2021, Grego "Ruel" Gaudia Degamo filed his Certificate of Candidacy as an independent candidate for the same office, and Pryde Henry A. Teves also filed for the gubernatorial contest. Roel petitioned the COMELEC to declare Ruel a nuisance candidate, alleging that Ruel used the surname Degamo and the nickname "Ruel" to confuse voters, that he lacked the means and political machinery to mount a serious campaign, and that he was not a Degamo by birth. Roel submitted affidavits, including one from Irna Gaudia Degamo and from Rifeniel and Nanchie Degamo, in support of his contentions. Ruel denied the allegations, asserted his bona fide intention to run, and maintained that he had always been known as Ruel G. Degamo.

Proceedings before the COMELEC

On December 16, 2021, the COMELEC Second Division declared Ruel a nuisance candidate and ordered his Certificate of Candidacy denied due course and cancelled. The Second Division found that Ruel had used the name "Ruel Degamo" only recently, that he was actually known as Grego or Gaudia, and that his candidacy would confuse the electorate and lacked bona fide intention. Ruel filed a Motion for Reconsideration on December 21, 2021. The motion was opposed, and the matter was referred to the En Banc. The motion remained pending when the May 9, 2022 elections were held.

Election Results and Post‑Election Acts

The official May 9, 2022 results showed Teves leading with 301,319 votes, Roel second with 281,773, and Ruel third with 49,953. Roel filed an urgent motion for early resolution of Ruel’s motion for reconsideration. On August 16, 2022, this Court granted Roel’s petition for mandamus and ordered the COMELEC En Banc to resolve the pending motion within ten days. On September 1, 2022, the COMELEC En Banc denied Ruel’s motion for reconsideration, affirmed the Second Division, and directed that votes cast for Ruel be counted in favor of Roel. The COMELEC issued an order of execution on September 27, 2022, which directed creation of a Special Provincial Board of Canvassers to amend canvass records, annul the proclamation of Teves, credit votes received by Ruel to Roel, and proclaim the candidate with the highest amended votes. The Special Provincial Board convened on October 3, 2022 and proclaimed Roel as Governor, and Roel took his oath on October 4, 2022.

The Petitions to the Supreme Court

After the COMELEC En Banc resolution and the order of execution, Teves filed a petition for certiorari on September 5, 2022, and Ruel filed a separate petition on September 6, 2022, both ascribing grave abuse of discretion to the COMELEC Second Division and En Banc and seeking injunctive relief. The Office of the Solicitor General filed a consolidated comment urging dismissal on grounds of mootness and asserting that the petitions were not the proper remedies to determine who was the rightful governor. The petitions were consolidated for resolution by this Court.

Parties’ Principal Contentions

Teves argued that the COMELEC committed grave abuse in declaring Ruel a nuisance candidate and in crediting Ruel’s 49,953 votes to Roel because Teves’s campaign and voters could not have been confused given Roel’s public profile, and because the vote differential was substantial. Teves also invoked alleged procedural anomalies, including a purported sham COMELEC resolution and the pendency of a separate disqualification case, Balasbas, et al. v. Degamo, which he asserted raised a prejudicial question. Ruel contended that the COMELEC En Banc acted with grave abuse by disregarding pending matters such as the Balasbas case, by failing to recognize that he was legitimately known as Ruel Degamo, and by imposing improper financial capacity requirements for candidacy; he invoked precedent that unaffiliated and unknown candidates are not necessarily nuisance candidates. Roel defended the COMELEC rulings, maintained that the evidence showed Ruel’s bad faith use of the surname and nickname, argued that the vote tally for Ruel evinced voter confusion, and asserted that Teves was not a real party in interest in the nuisance proceedings and therefore his due process claims failed. The COMELEC, through the OSG, argued that the petitions were moot in light of the En Banc resolution, execution, proclamation, and oath-taking, that the petitions sought improper remedies, and that petitioners failed to show grave abuse of discretion.

Issue Presented

This Court framed the singular issue as whether the COMELEC erred in declaring Ruel a nuisance candidate.

Ruling of the Supreme Court

The Court dismissed the petitions in G.R. No. 262622 and G.R. No. 262682 for lack of merit and held that the COMELEC En Banc did not commit grave abuse of discretion in SPA No. 21-085 (DC) dated September 1, 2022. The Court upheld the COMELEC’s factual findings that Ruel had used the name "Ruel Degamo" only recently, that he had not shown legitimate filiation as a Degamo, that he was known as Grego or Gaudia, and that his candidacy was intended to confuse voters. The Court sustained the crediting of the votes cast for Ruel to Roel pursuant to the COMELEC ruling and controlling jurisprudence.

Legal Basis and Reasoning

The Court reiterated that a petition for certiorari under Rule 64 in relation to Rule 65 tests whether the tribunal committed grave abuse of discretion amounting to lack or excess of jurisdiction. The Court defined grave abuse of discretion as capricious and whimsical exercise of judgment so patent and gross as to amount to an evasion of a positive duty. The Court emphasized its deference to factual findings of a specialized agency such as the COMELEC and declined to disturb those findings absent exceptional circumstances. The Court reviewed the statutory framework under the Omnibus Election Code, noting Sec. 69 authorizes the COMELEC to cancel candidacies motu proprio or upon verified petition and traced the historical development of remedies for electoral controversies. The Court surveyed its prior decisions — including Bautista, Martinez III, Dela Cruz, Zapanta, and Santos — and reiterated the consistent rule that votes cast for a nuisance candidate should be credited in favor of the legitimate candidate with a similar name to effectuate the will of the electorate and to avoid rewarding technical delays by nuisance operators. The Court addressed the burden of proof and shifting: Roel presented affidavits that tended to establish Ruel’s lack of filiation and bad faith, and the COMELEC reasonably required Ruel to produce primary evidence such as his birth certificate.

Case Syllabus (G.R. No. 262622)

Parties and Procedural Posture

Pryde Henry A. Teves filed a petition for certiorari challenging the COMELEC En Banc resolution declaring Grego "Ruel" G. Degamo a nuisance candidate and directing crediting of his votes to Roel R. Degamo.
Grego "Ruel" G. Degamo filed a separate petition for certiorari and injunctive relief contesting the same COMELEC En Banc action.
Commission on Elections (COMELEC) Second Division declared Ruel a nuisance candidate and the COMELEC En Banc affirmed that finding and ordered the votes credited to Roel.
This Court had earlier issued a writ of mandamus in G.R. No. 261178 ordering the COMELEC En Banc to resolve the pending motion for reconsideration, which was later deconsolidated from the present certiorari petitions.
The petitions in G.R. Nos. 262622 and 262682 were consolidated for resolution before the Supreme Court, En Banc.

Key Factual Allegations

Roel filed a petition before the COMELEC alleging that Ruel filed his Certificate of Candidacy to confuse voters because Ruel used the surname “Degamo” though he was allegedly a Gaudia, and adopted the nickname “Ruel” only for the 2022 elections.
Roel submitted affidavits alleging lack of filiation, lack of resources, and coercion surrounding Ruel’s filing.
Ruel answered that he possessed the qualifications to run, that he had always been known as Ruel G. Degamo, and that denying his COC would impose an impermissible property qualification.
On election day May 9, 2022, Ruel remained on the official ballot and received 49,953 votes while Teves received 301,319 votes and Roel received 281,773 votes.
After the COMELEC En Banc denial of Ruel’s motion for reconsideration, the COMELEC ordered a writ of execution to annul Teves’ proclamation and credit Ruel’s votes to Roel, after which a Special Provincial Board proclaimed Roel and he took his oath.

Procedural History

The COMELEC Second Division promulgated a December 16, 2021 resolution declaring Ruel a nuisance candidate and cancelling his COC.
Ruel filed a motion for reconsideration which the COMELEC En Banc denied on September 1, 2022, affirming the Second Division resolution and ordering that votes for Ruel be credited to Roel.
Roel sought and obtained a writ of mandamus from this Court directing COMELEC En Banc to resolve the pending motion for reconsideration within ten days.
Following the COMELEC En Banc action, the Commission issued an order of execution directing canvassers to amend canvass and credit votes, leading to the proclamation and oath of Roel.
Teves and Ruel filed certiorari petitions in this Court alleging grave abuse of discretion by the COMELEC En Banc.

Issues Presented

Whether the COMELEC En Banc committed grave abuse of discretion amounting to lack or excess of jurisdiction in declaring Ruel a nuisance candidate.
Whether the votes cast for Ruel should be credited to Roel despite the automated election system and despite Teves not being impleaded in the nuisance proceedings.
Whether procedural and evidentiary irregularities, including the pendency of other COMELEC matters and alleged forum shopping, precluded the COMELEC from resolving the nuisance petition as it did.

Ruling and Disposition

The Supreme Court dismissed the petitions for certiorari in G.R. Nos. 262622 and 262682 for lack of merit in the claim of grave abuse of discretion.
The Court held that the COMELEC En Banc did not commit grave abuse of discretion in declaring Ruel a nuisance candidate and in directing that votes received by Ruel