GR L 13403; (March, 1960) (Digest)
G.R. No. L-13403; March 23, 1960
RAMON E. SAURA, plaintiff-appellant, vs. ESTELA P. SINDICO, defendant-appellee.
FACTS
Ramon E. Saura and Estela P. Sindico were rivals for nomination as the official congressional candidate of the Nacionalista Party in the fourth district of Pangasinan for the November 12, 1957 elections. On August 23, 1957, they entered into a written agreement containing a pledge that each aspirant would respect the result of the party convention and that neither would run as a rebel or independent candidate after losing. In the provincial convention held on August 31, 1957, Saura was elected and proclaimed the party’s official candidate. Despite this, Sindico filed her certificate of candidacy with the Commission on Elections on September 6, 1957, and actively campaigned. Consequently, Saura filed a suit for damages on October 5, 1957. The lower court dismissed the complaint, ruling the agreement null and void because its subject matter—a public office—is not within the commerce of man, and the pledge curtailed the free exercise of the elective franchise, violating public policy.
ISSUE
Whether the agreement between Saura and Sindico, wherein they pledged not to run as rebel or independent candidates after losing the party nomination, is valid and enforceable.
RULING
No, the agreement is null and void. The Supreme Court affirmed the lower court’s dismissal of the complaint. Political rights, such as the right to present one’s candidacy and be voted into public office, are conferred for the public good and not for private benefit. These rights are excluded from the commerce of man and cannot be bargained away or curtailed by private agreement. The qualifications for public office are fixed by constitutional and statutory provisions and cannot be altered by private parties. Agreements that restrict a candidate’s withdrawal from a race, whether for nomination or election, are against public policy as they limit the choice of the electorate. The Court distinguished the cited cases of Pendleton vs. Pace and Monsale vs. Nico as inapplicable, as they did not involve agreements that restricted candidacy in violation of public policy. The order of dismissal was affirmed.