G.R. No. L-13069; May 28, 1958
JOVENCIO A. REYES, petitioner, vs. COMMISSION ON ELECTIONS and GODOFREDO S. REYES, respondents.

FACTS

Petitioner Jovencio A. Reyes is a registered candidate for Congressman of the Second District of Ilocos Sur in the 1957 elections, having filed his certificate of candidacy on August 20, 1957, which the Commission on Elections (COMELEC) initially agreed to give due course. On September 22, 1957, respondent Godofredo S. Reyes, another candidate for the same position, filed a petition with the COMELEC seeking the cancellation of petitioner’s certificate on the ground that it was filed in bad faith. The COMELEC conducted an investigation and found that petitioner had not been actively campaigning: he had no posters or streamers except one small poster in his hometown, had not held any political meetings or rallies in any of the district’s towns, was not conducting house-to-house campaigns, and was actually residing in Quezon City, with many people not having seen him for a long time. Based on these findings, the COMELEC decided that the certificate was filed in bad faith and refused to give it due course. The Supreme Court initially granted a preliminary injunction requiring the COMELEC to give due course to the certificate.

ISSUE

Whether the COMELEC acted in excess of its jurisdiction and/or with grave abuse of discretion in refusing to give due course to petitioner Jovencio A. Reyes’s certificate of candidacy on the sole ground that his lack of active campaigning demonstrated bad faith.

RULING

Yes. The Supreme Court granted the petition, made the preliminary injunction absolute, and held that the COMELEC’s refusal constituted an abuse of discretion and an act in excess of its jurisdiction. The Court ruled that:
1. Good faith is always presumed. A candidate’s failure to engage in common campaign activities (like holding rallies or distributing posters) does not prove bad faith. Such a choice could be motivated by a desire to avoid conventional campaigning based on high ethical principles or personal dignity, which is not inconsistent with good faith.
2. The COMELEC exceeded its powers by arrogating unto itself the prerogative to determine whether to give due course to a candidacy based on its own impressions about a candidate’s campaign efforts, even when the candidate possesses all the legal qualifications and none of the disqualifications. Citing Abcede vs. Imperial, the Court reiterated that the COMELEC’s duty to receive and give due course to certificates of candidacy is ministerial when the constitutional and statutory requirements are met. Its power is limited to administrative questions and does not extend to deciding matters involving the right to vote or to determine who among qualified candidates should be allowed to run.
3. This case is distinguishable from Garcia vs. Imperial, where the COMELEC’s refusal was sustained to prevent voter confusion due to similarity in candidate names. Here, no such confusion would arise given the great difference between the names of petitioner Jovencio A. Reyes and respondent Godofredo S. Reyes.
Costs were adjudged against respondent Godofredo S. Reyes.