The Supreme Court affirmed the Commission on Elections’ (COMELEC) decision to disqualify Ruel Gaudia Degamo as a nuisance candidate in the Negros Oriental gubernatorial race. By declaring Ruel a nuisance candidate and crediting his votes to Roel Degamo, the Court upheld the COMELEC’s authority to prevent voter confusion and ensure a faithful determination of the electorate’s true will. This decision reinforces the principle that election laws must be liberally construed to effectuate the voters’ intent, even in automated election systems where candidate name similarity can cause confusion.

Ballot Confusion: How Similar Names Can Sway an Election

The consolidated cases of Teves v. COMELEC and Degamo v. COMELEC arose from the 2022 Negros Oriental gubernatorial elections. Roel Degamo filed a petition to declare Ruel Degamo a nuisance candidate, arguing that Ruel’s candidacy aimed to confuse voters due to the similarity in names. The COMELEC Second Division initially granted the petition, a decision affirmed by the COMELEC En Banc, leading to Ruel’s disqualification and the crediting of his votes to Roel. This ruling prompted separate petitions from Pryde Henry Teves, who initially won the election, and Ruel Degamo, challenging the COMELEC’s decision.

At the heart of the legal battle was Section 69 of the Omnibus Election Code, which empowers the COMELEC to refuse or cancel a certificate of candidacy if it is filed to mock the electoral process, cause voter confusion, or without a bona fide intention to run. The Supreme Court’s analysis hinged on whether the COMELEC committed grave abuse of discretion in applying this provision. As the Court explained, grave abuse of discretion implies an arbitrary or despotic exercise of power, not merely an error in judgment. It emphasizes that the COMELEC, as a specialized agency, must be accorded deference in its factual findings and decisions, unless a clear abuse of discretion is proven.

The Court found that the COMELEC did not err in determining Ruel Degamo as a nuisance candidate. Central to this was the COMELEC’s finding that Ruel acted in bad faith by using the name “Ruel Degamo,” as he was known as Grego Gaudia and had not consistently used the Degamo surname. The Supreme Court also highlighted Ruel’s failure to present his birth certificate, which would have been the best evidence to prove his filiation with the Degamo family. This failure triggered the application of Section 3(e) of Rule 131 of the Rules of Evidence, which presumes that evidence willfully suppressed would be adverse if produced.

Section 3. Disputable presumptions. — The following presumptions are satisfactory if uncontradicted, but may be contradicted and overcome by other evidence:

x x x x

(e) That evidence willfully suppressed would be adverse if produced;

The Court stressed that in nuisance candidate cases, a key consideration is the candidate’s seriousness in running for office. Because the burden of evidence was shifted to Ruel to demonstrate his bona fide intent, his failure to present critical evidence undermined his claim. The Court emphasized the potential for voter confusion due to the similarity between “Roel Degamo” and “Ruel Degamo”, even in an automated election system.

Building on this, the Court cited several precedents, including Bautista v. COMELEC and Martinez v. House of Representatives Electoral Tribunal, where candidates were disqualified due to confusingly similar names. It underscored that even automated elections are not immune to voter confusion caused by nuisance candidates. By failing to show that using “Ruel Degamo” was not intended to confuse voters, Ruel did not demonstrate his intent was legitimate.

An important aspect of the case was the issue of due process for Pryde Henry Teves, who was not a party to the nuisance candidate proceedings. The Court clarified that unaffected candidates, like Teves, are mere observers in such cases, meaning their rights are not violated by not being directly involved.

Thus, when a verified petition for disqualification of a nuisance candidate is filed, the real parties-in-interest are the alleged nuisance candidate and the interested party, particularly, the legitimate candidate. Evidently, the alleged nuisance candidate and the legitimate candidate stand to be benefited or injured by the judgment in the suit. The outcome of the nuisance case shall directly affect the number of votes of the legitimate candidate, specifically, whether the votes of the nuisance candidate should be credited in the former’s favor.

Accordingly, the Court held that Teves’s non-participation did not invalidate the COMELEC’s proceedings. The decision reinforces the principle that the primary concern is ensuring a fair election between the legitimate candidates.

The Supreme Court upheld the crediting of Ruel Degamo’s votes to Roel Degamo. It cited Zapanta v. COMELEC, which clarified how votes for nuisance candidates should be treated in multi-slot and single-slot offices. The Court reiterated that the goal is to prevent voter disenfranchisement and uphold the will of the electorate. While automated elections present a different context than manual elections, the underlying principle remains: nuisance candidates create confusion, and their votes should be counted in favor of the legitimate candidate to reflect voter intent accurately.

Therefore, the ruling in Teves v. COMELEC reinforces the COMELEC’s authority to disqualify nuisance candidates, especially when their names are confusingly similar to those of legitimate candidates. The Supreme Court emphasized that the COMELEC’s decisions must be based on factual findings and are entitled to deference, absent a clear showing of grave abuse of discretion. The COMELEC must diligently assess the candidate’s intent, considering factors such as name usage and the presentation of evidence. The decision also confirms that non-participation of other candidates will not invalidate nuisance proceedings, which focuses on ensuring a fair election between the legitimate candidates.

FAQs

What was the key issue in this case?	The key issue was whether the COMELEC committed grave abuse of discretion in declaring Ruel Degamo a nuisance candidate and crediting his votes to Roel Degamo. The Supreme Court had to determine if the COMELEC acted within its authority under the Omnibus Election Code.
What is a nuisance candidate?	A nuisance candidate is someone who files a certificate of candidacy to mock the election process, cause confusion among voters, or without a bona fide intention to run. The COMELEC can disqualify such candidates to ensure a fair and accurate election.
Why was Ruel Degamo declared a nuisance candidate?	Ruel Degamo was declared a nuisance candidate because he was known as Grego Gaudia and had not consistently used the Degamo surname. Additionally, the COMELEC found that he acted in bad faith and did not have a bona fide intention to run for governor.
What happens to the votes of a nuisance candidate?	The Supreme Court upheld that the votes cast for a nuisance candidate should be credited to the legitimate candidate with a similar name. This ensures that the true will of the electorate is upheld and that votes intended for the legitimate candidate are not wasted.
Did Pryde Henry Teves have a right to be involved in the nuisance case?	The Court clarified that other candidates (like Teves) who do not have similarity of names with the nuisance candidate are mere observers in such cases and are not considered real parties-in-interest. Therefore, their rights are not violated by not being directly involved in the nuisance case.
What evidence did Ruel Degamo fail to present?	Ruel Degamo failed to present his birth certificate, which would have been the best evidence to prove his filiation with the Degamo family. This failure led the Court to presume that the evidence, if produced, would be adverse to his case.
What is the role of the COMELEC in these cases?	The COMELEC is tasked with supervising elections and has the authority to disqualify nuisance candidates. The Supreme Court gives deference to the COMELEC’s decisions unless there is a clear showing of grave abuse of discretion.
How do automated elections affect the rules on nuisance candidates?	Even in automated elections, the Supreme Court recognizes that nuisance candidates can cause voter confusion. The same rules apply, and the votes for nuisance candidates should be credited to the legitimate candidate with a similar name.

In conclusion, Teves v. COMELEC illustrates the importance of maintaining the integrity of elections by preventing voter confusion. The decision underscores the COMELEC’s vital role in ensuring that candidates act in good faith and that the true will of the electorate is accurately reflected in election results.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Teves vs. COMELEC, G.R. No. 262622, February 14, 2023