G.R. No. 230744. September 26, 2017
MARIO O. SALVADOR, PETITIONER, VS. COMMISSION ON ELECTIONS AND ALEXANDER S. BELENA, RESPONDENTS.

FACTS

Petitioner Mario O. Salvador was a mayoralty candidate in San Jose City, Nueva Ecija, during the 2010 elections. He was a member of the Bagong Lakas ng Nueva Ecija political party. His opponent, Marivic Violago-Belena, won the election. In 2014, private respondent Alexander Belena, the spouse of the winning candidate, filed a complaint-affidavit against Salvador for alleged overspending in violation of election laws. Belena contended that based on Salvador’s filed Statement of Election Contribution and Expenditure (SOCE), he spent P449,000.00. Given the registered voters of 91,889 and applying the statutory limit of P3.00 per voter for a candidate belonging to a political party under Section 13 of Republic Act No. 7166, Belena argued the lawful expenditure cap was only P275,667.00, thus showing an excess.
Salvador defended himself by arguing that while he was a party member, he received no support from the party. He invoked the exception under the same law, which allows a candidate “without any political party and without support from any political party” to spend P5.00 per voter. The COMELEC En Banc, in its assailed Resolutions, found probable cause and directed the filing of an information against Salvador. It ruled that the higher P5.00 limit applies only to a candidate who simultaneously satisfies two conditions: not being a member of any political party AND not receiving support from any political party. Since Salvador was a party member, the COMELEC applied the lower P3.00 limit.

ISSUE

Did the COMELEC En Banc commit grave abuse of discretion in finding probable cause against Salvador for election overspending?

RULING

The Supreme Court ruled in the negative, upholding the COMELEC’s finding of no grave abuse of discretion. The Court affirmed the COMELEC’s strict, literal interpretation of Section 13 of R.A. No. 7166, which amended Section 100 of the Omnibus Election Code. The legal logic hinges on the principle of verba legis—that when the language of a statute is clear and unambiguous, it must be applied exactly as written, without interpretation. The provision states: “a candidate without any political party and without support from any political party may be allowed to spend Five Pesos (P5.00) for every such voter.” The use of the conjunctive “and” is decisive; it means both conditions must concur for the exception to apply.
Salvador’s claim that he received no support, while being a party member, is irrelevant. The law explicitly requires the candidate to be “without any political party” as a primary condition. His membership in Bagong Lakas ng Nueva Ecija immediately disqualifies him from availing of the higher expense limit. The law’s intent is clear: to grant a more liberal spending cap only to genuinely independent candidates who lack the machinery and resources of an organized party. Therefore, the applicable limit was P3.00 per voter. His admitted expenditure of P449,000.00 exceeded the computed limit of P275,667.00, establishing probable cause for violation. The COMELEC’s action was a proper exercise of its constitutional mandate to enforce election laws and was grounded on a correct reading of the statute.