G.R. No. 260116 , July 11, 2023
MAYOR AGNES VILLANUEVA, NOW INCUMBENT MEMBER OF THE SANGGUNIANG PANLALAWIGAN OF MISAMIS OCCIDENTAL, PETITIONER, VS. HONORABLE COMMISSION ON ELECTIONS, EN BANC, AND THE LAW DEPARTMENT OF THE COMELEC, MANILA, RESPONDENTS.

FACTS

Petitioner Agnes C. Villanueva was the Mayor of Plaridel, Misamis Occidental. On October 29, 2010, she requested the COMELEC to reassign Municipal Election Officer Amado B. Quiza, citing alleged neglect of duty and abuse of authority related to voter registration and the demotion of a BEI chairperson. She also stated Quiza would only be accommodated in the municipal premises until November 15, 2010. On that date, she ordered the closure of the municipal election office. In subsequent letters, she extended the accommodation until December 31, 2010, offered to shoulder rentals for a new office, and later, on January 26, 2011, informed COMELEC that Quiza would no longer be accommodated, arguing the COMELEC had the primary duty to provide office space under Section 55 of the Omnibus Election Code (OEC). On February 15, 2011, the COMELEC Law Department (CLD) filed a complaint against Villanueva for violating Section 261(f) of the OEC (coercion of election officers). The CLD recommended filing charges, finding the closure disrupted Quiza’s official duties. The COMELEC En Banc, in a Resolution dated December 11, 2015, approved the recommendation and directed the filing of an information. Villanueva’s motion for reconsideration was denied in a Resolution dated January 21, 2022. Villanueva filed a petition for certiorari before the Supreme Court, arguing the offense under Section 261(f) can only be committed during an election period, prescription had set in, there was inordinate delay in resolving the case, and she acted in good faith based on legitimate grievances against Quiza.

ISSUE

Whether the COMELEC committed grave abuse of discretion in finding probable cause to indict petitioner Villanueva for violation of Section 261(f) of the Omnibus Election Code.

RULING

The Supreme Court granted the petition and nullified the COMELEC Resolutions. The Court ruled that the COMELEC committed grave abuse of discretion. Applying the precedent set in Peñas v. COMELEC, the Court held that the offense of coercion of election officers under Section 261(f) of the OEC requires a direct relation to an election. The provision’s intent is to protect the conduct of elections, and the coercive act must be performed to influence the election officer’s exercise of their functions in connection with an election. The closure of the election office in this case, which occurred after the 2010 elections and was motivated by a request for reassignment of personnel, was not shown to be for the purpose of interfering with Quiza’s election-related duties. Furthermore, the Court found inordinate delay in the proceedings. The complaint was filed in 2011, the CLD recommended charges in 2015, the COMELEC En Banc acted on it five years later in 2015, and it took another six years to resolve the motion for reconsideration in 2022, without any justification for the delays, violating Villanueva’s right to due process and a speedy disposition of her case. The Court also noted that the Office of the Ombudsman had previously dismissed related administrative and criminal complaints against Villanueva based on the same facts.