G.R. No. 258456, July 26, 2022
GIORGIDI B. AGGABAO AND AMELITA S. NAVARRO, PETITIONERS, VS. COMMISSION ON ELECTIONS (COMELEC) AND LAW DEPARTMENT, RESPONDENTS.

FACTS

Amelita Navarro filed her Certificate of Candidacy (COC) for Mayor of Santiago City, Isabela, for the 2022 elections, stating she was the official nominee of Partido Reporma and attaching a Certificate of Nomination and Acceptance (CONA) signed by its Chairman, Senator Panfilo Lacson. Subsequently, Christopher Ayson also filed a COC for the same position, claiming nomination from the same party. Senator Lacson formally informed the COMELEC Law Department that Partido Reporma had not issued any CONA to Ayson and affirmed Navarro as its sole official candidate. Navarro later withdrew her candidacy for mayor to run for vice-mayor, and Giorgidi Aggabao filed a COC as her substitute candidate, presenting a CONA from Partido Reporma.
The COMELEC Law Department, however, issued documents declaring Navarro an independent candidate and denying due course to Aggabao’s substitution. It invoked Section 15 of COMELEC Resolution No. 10717, which states that if a party nominates more candidates than allowed for a position, all such nominations shall be denied due course, and the aspirants shall be deemed independent. The Department ruled that since both Navarro and Ayson claimed the party’s nomination, the party had effectively nominated two candidates for a single seat, triggering the rule.

ISSUE

Whether the COMELEC Law Department committed grave abuse of discretion in applying Section 15 of COMELEC Resolution No. 10717 to declare Navarro an independent candidate and deny Aggabao’s COC, based solely on Ayson’s claim of nomination despite the party chairman’s categorical disavowal of that claim.

RULING

Yes, the COMELEC Law Department committed grave abuse of discretion. The Supreme Court En Banc granted the petition, nullifying the assailed documents. The legal logic is anchored on the nature of the COMELEC’s powers and the evidentiary basis for its actions. The COMELEC possesses quasi-judicial powers and must exercise them with due process and based on substantial evidence. Here, the Law Department mechanically applied Section 15 based merely on the facial existence of two COCs claiming the same party affiliation, without conducting a factual inquiry into the veracity of those claims.
The party chairman’s official communication, a notarized certification, constituted prima facie evidence that only Navarro was legitimately nominated. By ignoring this evidence and failing to verify Ayson’s spurious claim, the Department acted arbitrarily. Its function is ministerial only when no cloud of doubt exists; where a legitimate challenge is presented, it must elevate the matter for the COMELEC’s quasi-judicial resolution. The Department’s action effectively disenfranchised the political party’s right to select its official candidate and the substitute’s right to run under its banner without a hearing. Consequently, the Supreme Court ruled that the proper course was for the COMELEC, in the exercise of its adjudicatory powers, to hear the controversy, not for its Law Department to preemptively disqualify the genuine party nominee based on an unrebutted, fraudulent claim.