G.R. No. 225152 , October 5, 2021
PARTIDO DEMOKRATIKO PILIPINO-LAKAS NG BAYAN (PDP-LABAN) HEREIN REPRESENTED BY ITS SECRETARY-GENERAL, CONG. PANTALEON “BEBOT” ALVAREZ, PETITIONER, VS. COMMISSION ON ELECTIONS EN BANC, RESPONDENT.

FACTS

The Commission on Elections (COMELEC) issued Resolution No. 9991 on October 2, 2015, prescribing guidelines for the submission of Statements of Contributions and Expenditures (SOCEs) for the May 9, 2016 elections, setting a “final and non-extendible” deadline of June 8, 2016, pursuant to Section 14 of Republic Act No. 7166 , which requires filing within 30 days after the election. On June 23, 2016, the COMELEC En Banc issued Resolution No. 10147, extending the filing deadline to June 30, 2016, and exempting submissions by that date from administrative liability. The COMELEC justified the extension based on received requests, its past practice of extending deadlines in the 2010 and 2013 elections, and its interpretation that the law’s phrase “until he has filed the statement” implies SOCEs may be filed beyond the 30-day period to avoid frustrating the people’s mandate and creating a vacuum in public service. The Partido Demokratiko Pilipino-Lakas ng Bayan (PDP-Laban) filed a Petition for Certiorari, arguing the COMELEC exceeded its rule-making authority and violated the mandatory period under RA 7166. The COMELEC defended its action, stating the 30-day period is extendible, and it possesses broad enforcement powers. The Office of the Solicitor General disagreed, stating the period is mandatory. Intervenors Peralta, et al., supported the petitioner, arguing delay allows fabrication of SOCEs and winning candidates who fail to meet the deadline should be barred from office.

ISSUE

Whether the Commission on Elections (COMELEC) committed grave abuse of discretion when it extended the deadline for the submission of Statements of Contributions and Expenditures (SOCEs) through Resolution No. 10147.

RULING

Yes, the COMELEC committed grave abuse of discretion. The Supreme Court granted the petition, annulling COMELEC Resolution No. 10147. The Court ruled that Section 14 of RA 7166 is clear, mandatory, and jurisdictional: the SOCE must be filed within 30 days after the election. This period is not extendible. The COMELEC’s interpretation that the phrase “until he has filed” allows filing beyond the deadline is erroneous; that phrase refers to the prohibition on assuming office until the SOCE is filed, but the filing must still occur within the 30-day period. The COMELEC’s power to promulgate rules cannot contravene or diminish substantive law. By extending the deadline, the COMELEC effectively amended RA 7166, which it cannot do. Its past practice of granting extensions does not legitimize the act, as a violation of law is not validated by repetition. The Court emphasized that the 30-day deadline is crucial to the law’s purpose of ensuring timely transparency in campaign finance. The COMELEC’s fear of creating a vacuum in public office was misplaced, as the law itself provides the consequence—the winning candidate cannot assume office until the SOCE is filed—which is a matter of legislative policy.