G.R. No. 244027 , April 11, 2023
JOVIT BUELLA Y ABALAIN, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

Five separate Informations were filed before the Regional Trial Court (RTC) of Naga City, Branch 61, against Matea C. Obay, Jeffrey A. Esperas, Ruel A. Valencia, Joel C. Pastorizo, and petitioner Jovit A. Buella for violation of COMELEC Resolution No. 10015, in relation to Section 261(q) of the Omnibus Election Code and Section 32 of Republic Act No. 7166 . The charge involved illegal possession, custody, and control of bladed instruments during the May 9, 2016 election period. Specifically, petitioner was accused of possessing a black folding knife without a written permit from the COMELEC. Upon arraignment, all accused pleaded not guilty. Obay and Esperas filed a Motion to Dismiss, alleging that Section 1(a), Rule II, in relation to Section 1(f), Rule I of COMELEC Resolution No. 10015 is unconstitutional for including “all types of bladed instruments” in the definition of “deadly weapon,” arguing it went beyond the scope of the enabling law, violated due process and equal protection, and imposed an impossible permit requirement. The RTC granted the motion, declared the cited provisions unconstitutional insofar as they include all bladed instruments, and dismissed the cases. The RTC subsequently issued separate Orders dismissing the cases against Valencia, petitioner, and Pastorizo based on the same ruling. The prosecution’s motion for reconsideration was denied. The People, through the Office of the Solicitor General, filed a Petition for Certiorari before the Court of Appeals (CA). The CA granted the petition, annulled the RTC’s resolutions and orders, and remanded the cases for further proceedings, holding that the RTC committed grave abuse of discretion by allowing a collateral attack on the COMELEC Resolution’s constitutionality and by erroneously declaring it unconstitutional.

ISSUE

Whether the Court of Appeals erred in annulling the Regional Trial Court’s Resolutions and Orders which declared Section 1(a), Rule II, in relation to Section 1(f), Rule I of COMELEC Resolution No. 10015 unconstitutional and dismissed the criminal cases against the accused.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Decision of the Court of Appeals. The Court held that the RTC committed grave abuse of discretion in declaring COMELEC Resolution No. 10015 unconstitutional. The Court ruled that: (1) The COMELEC acted within its rule-making power under Section 52(i) of the Omnibus Election Code and Section 32 of R.A. No. 7166 in promulgating Resolution No. 10015, which includes bladed instruments in the ban on carrying deadly weapons during the election period. The inclusion of bladed instruments is a valid exercise of the COMELEC’s mandate to ensure free, orderly, honest, peaceful, and credible elections, as these instruments can be used to disrupt the electoral process. (2) The COMELEC Resolution is not an invalid exercise of delegated legislative power. It does not amend or expand the law but implements it by providing specific details, such as defining “deadly weapons” to include bladed instruments, which is consistent with the legislative intent to prevent election-related violence. (3) The Resolution does not violate substantive due process. The prohibition is a reasonable restriction to curb election violence, and the permit requirement is a valid regulatory measure, not an impossible condition, as the COMELEC has the authority to issue exemptions. (4) The Resolution does not violate the equal protection clause. The classification between those who bear firearms and those who bear bladed instruments is based on substantial distinctions (both are deadly weapons capable of disrupting elections) and is germane to the purpose of preventing election violence. The uniform application of the ban to all deadly weapons, including bladed instruments, is reasonable. The Court emphasized that the constitutionality of COMELEC Resolution No. 10015 is upheld.