G.R. No. 261107 , January 30, 2024
ANA LIZA ARRIOLA PERALTA, PETITIONER, VS. COMMISSION ON ELECTIONS, REPRESENTED BY THE CAMPAIGN FINANCE UNIT, RESPONDENT.

FACTS

Petitioner Ana Liza A. Peralta was a candidate for Mayor of San Marcelino, Zambales, in the May 2010 elections. The municipality had 20,301 registered voters, setting the statutory campaign expenditure limit at PHP 60,903.00 (PHP 3.00 per voter under Section 100 of the Omnibus Election Code, as amended by R.A. 7166). The COMELEC’s Campaign Finance Unit found that Peralta’s filed Statement of Contributions and Expenditures (SOCE) reflected total expenses of PHP 285,500.00, exceeding the limit by PHP 224,597.00. Following a directive to explain, Peralta submitted affidavits from contributors alleging clerical errors in the SOCE, such as mistaken entries (e.g., PHP 30,000 written instead of PHP 3,000) and misclassified expenses (e.g., amounts for voter list preparation erroneously reported as “meals and snacks”). She also cited health issues and logistical difficulties in verifying the records.
Disregarding these explanations, the COMELEC filed a motu proprio complaint for election overspending. Its Law Department found probable cause, a finding affirmed by the COMELEC En Banc in its assailed Resolutions dated August 8, 2018, and July 14, 2021. The COMELEC ordered the filing of an Information against Peralta for violation of Section 100 in relation to Section 262 of the Omnibus Election Code. Peralta then filed this Petition for Certiorari, arguing the COMELEC committed grave abuse of discretion.

ISSUE

Did the COMELEC commit grave abuse of discretion in finding probable cause to prosecute Peralta for election overspending based on her originally filed SOCE, despite her subsequent submissions seeking to correct it?

RULING

No, the COMELEC did not commit grave abuse of discretion. The Supreme Court emphasized that a finding of probable cause requires only a reasonable belief that a crime has been committed and the accused is probably guilty thereof. It is an executive function, and in petitions for certiorari, the Court’s review is limited to determining whether the COMELEC acted without or in excess of jurisdiction or with grave abuse of discretion amounting to lack or excess of jurisdiction. Grave abuse of discretion implies a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction.
The Court ruled that the COMELEC acted within its discretion in relying on the official SOCE filed by Peralta. The sworn SOCE constitutes the official and binding record of campaign finances. The alleged corrections, submitted years later via unverified affidavits, were properly considered by the COMELEC as matters of defense best threshed out in a full-blown trial, not during the preliminary determination of probable cause. The COMELEC was not obligated to accept these belated corrections at the investigatory stage. Its decision to proceed with prosecution based on the prima facie case established by the discrepant SOCE was a rational exercise of its mandate to enforce election laws. Consequently, the COMELEC’s actions were neither arbitrary nor capricious and thus, devoid of grave abuse of discretion. The Petition was dismissed.