G.R. No. 52713 - Yason vs. Commission on Elections

Case Summary (G.R. No. 52713)

Petitioner’s Claims

Gelacio I. Yason filed a petition for certiorari and mandamus to contest his disqualification by COMELEC. He sought to overturn the resolution that denied his candidacy based on his alleged change of party affiliation, declare the votes cast in his favor as valid rather than stray votes, and ultimately proclaim him as the elected Mayor due to his majority in the election.

Context of Candidacy Changes

On January 4, 1980, Yason initially filed his certificate of candidacy aligned with the Nationalista Party. However, he later amended this by erasing his affiliation with the Nationalista Party and asserting his candidacy under the Kilusang Bagong Lipunan (KBL) prior to the election. This alteration was formally documented by Yason through a telegram and a letter sent to COMELEC, where he disclaimed any knowledge of being nominated by the Nationalista Party.

Election Results and Disqualification Petition

The election took place on January 30, 1980, wherein Yason received 3,933 votes against Suarez's 3,568 votes. Following the election, Suarez filed a petition for Yason's disqualification, alleging turncoatism. This petition was accepted by COMELEC, which subsequently ruled that all votes for Yason would be considered stray, thereby declaring Suarez the mayor.

Jurisdictional Issues Raised by Yason

Yason contended three principal issues: (1) that after the election and proper canvassing of votes, COMELEC had no further jurisdiction to disqualify him; (2) that the petition for disqualification was untimely; and (3) that he was denied due process.

Interpretation of Turncoatism

The court examined the provision on turncoatism outlined in the 1973 Philippine Constitution and clarified that it prohibits elective public officials from changing party affiliations within a certain time frame before or after an election. However, the court stressed the importance of respecting the electorate's choice and the necessity of ensuring valid participation among voters.

Court’s Findings on Turncoatism

The court found insufficient evidence to classify Yason as a turncoat. His actions preceding the election indicated a clear choice to run under KBL. The law does not prevent candidates from altering their party affiliations until the elections, affirming that Yason's certification changes were valid and legally binding.

Filing Deadline for Disqualification

The court underscored the importance of timely filing regarding disqualification petitions. Suarez's petition was submitted past the designated deadline, thus invalidating it. This upheld the principle that such petitions must be filed before elections to facilitate a fair electoral process.

Judicial Discretion and Political Dynamics

The ruling highli