G.R. No. 265847 , August 6, 2024
MA. ZARAH ROSE DE GUZMAN-LARA, PETITIONER, VS. COMMISSION ON ELECTIONS AND MANUEL N. MAMBA, RESPONDENTS.

FACTS

During the May 2022 National and Local Elections, petitioner Ma. Zarah Rose De Guzman-Lara and private respondent Manuel N. Mamba were candidates for Governor of Cagayan. Lara filed a Petition for Disqualification against Mamba on May 10, 2022, alleging massive vote-buying and unlawful disbursement of public funds in violation of Section 68 of the Omnibus Election Code (OEC). Specifically, she averred that Mamba, as incumbent Governor, used provincial funds to distribute cash assistance (“ayuda”) under various programs during the campaign period from March 25 to May 8, 2022. On May 11, 2022, Mamba was proclaimed the duly elected Governor. The COMELEC Second Division, in a Resolution dated December 14, 2022, granted Lara’s petition and disqualified Mamba, finding substantial evidence of a violation of Section 261(v) of the OEC (prohibited release of public funds 45 days before an election). Mamba filed a Motion for Partial Reconsideration. The COMELEC En Banc, in its assailed Resolution dated March 6, 2023, dismissed the Petition for Disqualification for lack of jurisdiction. It ruled that under COMELEC Resolution No. 10673, Lara’s petition filed via email on May 10, 2022, at 6:21 p.m. was deemed filed at 8:00 a.m. on May 11, 2022, which was after Mamba’s proclamation at 1:39 a.m. on the same day. The COMELEC En Banc held that the proclamation divested it of jurisdiction to hear the disqualification case, making it the wrong remedy. Lara filed the instant Petition for Certiorari, arguing the COMELEC committed grave abuse of discretion.

ISSUE

Whether the COMELEC En Banc committed grave abuse of discretion amounting to lack or excess of jurisdiction (1) in dismissing the Petition for Disqualification for lack of jurisdiction, and (2) in not affirming the COMELEC Second Division’s Resolution disqualifying Mamba.

RULING

Yes, the COMELEC En Banc committed grave abuse of discretion. The Petition is meritorious.
1. On Procedural Grounds: The COMELEC should have granted due course to the Petition for Disqualification by exercising liberality in the application of its procedural rules. Its rigid application of COMELEC Resolution No. 10673—deeming the electronically filed petition as filed at 8:00 a.m. on May 11, 2022, and thus after Mamba’s 1:39 a.m. proclamation—was capricious and arbitrary. The rule on electronic filing is a procedural tool for efficiency, not a weapon for technical dismissal. Given that only about seven hours lapsed between the actual email filing (6:21 p.m., May 10) and the proclamation (1:39 a.m., May 11), and considering the gravity of the allegations involving the integrity of elections and misuse of public funds, the COMELEC should have relaxed its rules to serve substantial justice. Technicalities should not override the duty to resolve disqualification cases on their merits, especially when filed before proclamation.
2. On Jurisdictional Grounds: The COMELEC En Banc erred in ruling it lost jurisdiction due to the proclamation. Jurisdiction over a disqualification case, once acquired, is not lost by the mere fact of a candidate’s subsequent proclamation. The COMELEC retains the authority to disqualify a candidate and order the suspension of their proclamation, or annul a proclamation made pending its decision. The proper remedy to question the eligibility of a proclaimed winner is not exclusively a quo warranto petition; a disqualification case can still proceed. The COMELEC’s dismissal based on a perceived loss of jurisdiction constituted a patent evasion of its positive duty to adjudicate the substantive allegations of election offenses.
The Supreme Court found the COMELEC’s dismissal to be a capricious, arbitrary, and whimsical exercise of judgment equivalent to an excess or lack of jurisdiction. The COMELEC gravely abused its discretion in refusing to resolve the disqualification case on its merits based on a rigid and technical application of procedural rules, thereby redirecting the COMELEC’s course along constitutional channels. The case was remanded to the COMELEC for further proceedings.