G.R. No. 258448 . July 05, 2022.
WILSON CARITERO AMAD, PETITIONER, VS. COMMISSION ON ELECTIONS, RESPONDENT.

FACTS

Petitioner Wilson Caritero Amad filed his Certificate of Candidacy for Vice President for the May 2022 elections. The COMELEC, motu proprio, filed a petition to declare him a nuisance candidate, alleging he lacked a genuine intention to run, had no nationwide network or substantial voter base, and was virtually unknown outside his locality. The COMELEC First Division granted the petition, canceling his COC, reasoning that a national candidate must have an organized, nationwide support system, which Amad failed to demonstrate despite his regional advocacy work and social media use.
Amad filed a Motion for Reconsideration via email on December 20, 2021, at 5:00 p.m., paid the required fees, and received acknowledgment from the COMELEC Clerk. However, the COMELEC En Banc issued two orders on January 3, 2022. The first noted his payment, but the second denied his motion, deeming it filed out of time at 5:01 p.m., unverified, and lacking proof of payment. Amad filed a Petition for Certiorari before the Supreme Court, arguing grave abuse of discretion regarding the procedural denial and the substantive declaration as a nuisance candidate.

ISSUE

The primary issue was whether the COMELEC committed grave abuse of discretion in denying Amad’s Motion for Reconsideration on procedural grounds and in declaring him a nuisance candidate based on perceived lack of nationwide political machinery and intent.

RULING

The Supreme Court dismissed the petition as moot and academic because the May 2022 elections had already been held. However, the Court addressed the substantive issues to provide guidance. On the procedural issue, the Court found the COMELEC En Banc’s denial of the motion for reconsideration constituted grave abuse of discretion. The records clearly showed the motion was filed and verified on time, with proof of payment duly acknowledged. The COMELEC’s contradictory orders—one noting payment and another denying for lack thereof—demonstrated arbitrariness. The Court emphasized that election cases involve public interest, warranting a liberal application of procedural rules to uphold substantive rights.
On the substantive issue, the Court held the COMELEC committed grave abuse of discretion in declaring Amad a nuisance candidate. The legal standard under Section 69 of the Omnibus Election Code requires a finding that the candidacy was filed to put the election process in mockery or disrepute, or to cause confusion among voters by similarity of names. The COMELEC’s basis—lack of political machinery, financial capacity, or nationwide popularity—exceeded this statutory definition. The Court ruled that the absence of a political party or national network does not equate to a lack of bona fide intention to run. Such factors are not legal qualifications and cannot be used to disqualify a candidate, as they undermine the constitutional right to suffrage and the opportunity for public service. The COMELEC substituted its own standards for the law, thereby acting without jurisdiction.