G.R. No. L-52390, March 31, 1981
MANUEL I. SANTOS, petitioner, vs. COMMISSION ON ELECTIONS, RICARDO NAVAL and JUANITO P. FRANCISCO, respondents.

FACTS

Petitioner Manuel I. Santos was the official Nacionalista Party (NP) candidate for Mayor of Taytay, Rizal, in the January 30, 1980 elections. Private respondents filed a petition for his disqualification with the Commission on Elections (COMELEC) on January 14, 1980, alleging “political turncoatism.” The COMELEC, in its Resolution dated January 19, 1980, disqualified Santos. It found that Santos had submitted a letter of resignation dated January 2, 1980, as a member of the Municipal Committee of the Kilusang Bagong Lipunan (KBL) in Taytay, Rizal. The NP, through its Acting President, had initially revoked his nomination because he was a member in good standing of the KBL as of January 2, 1980, citing constitutional provisions against turncoatism and Presidential Decree No. 1661 against “guest candidates.” Despite this initial revocation, Santos was later chosen as the NP’s official candidate.
Santos argued before the Supreme Court that he had always been an NP member and never ceased to be one. He contended that the KBL was not a political party but merely an “umbrella organization” or a movement of the New Society, so joining it did not constitute changing political party affiliation. He also claimed the COMELEC resolution was not supported by substantial evidence.

ISSUE

Whether the COMELEC committed a grave abuse of discretion in disqualifying petitioner Manuel I. Santos as a candidate for mayor on the ground of political turncoatism.

RULING

The Supreme Court dismissed the petition and upheld the COMELEC Resolution. The Court’s power of review over COMELEC decisions via certiorari is confined to questions of law, such as violations of the Constitution or denial of due process. The Court found no denial of procedural due process, as Santos was given notice, filed an Answer, and his evidence was admitted and evaluated by the COMELEC.
On the substantive issue, the Court ruled that the COMELEC’s finding of disqualification was supported by substantial evidence, satisfying the requirements of due process. The act of tendering a formal resignation from the KBL Municipal Committee was a clear overt act demonstrating prior affiliation with the KBL. This act would have been unnecessary if the KBL were not a distinct political aggrupation. The Court noted the striking similarity of this case with Evasco vs. COMELEC, where a similar resignation from the KBL was deemed sufficient evidence of prior affiliation. The Court rejected Santos’s argument that the KBL was not a political party, noting that the COMELEC had accredited the NP and KBL separately in the 1978 elections, indicating they were distinct political entities. Therefore, by actively joining the KBL and later affiliating with the NP within six months before the election, Santos violated Section 10, Article XII(C) of the 1973 Constitution and PD No. 1661, which prohibit changing political party affiliation within six months immediately preceding an election.