The Supreme Court ruled that the Commission on Elections (COMELEC) committed grave abuse of discretion when it failed to conduct a hearing to resolve conflicting claims regarding party endorsements in a local election. This decision emphasizes the importance of due process and the right to a hearing, even in administrative matters related to elections. The Court nullified COMELEC’s resolutions that denied a candidate’s substitution due to the agency’s failure to properly investigate and adjudicate which candidate was the legitimate nominee of a political party.

Navigating the Nomination Maze: When Should COMELEC Investigate a Candidate’s Claim?

The case of Aggabao v. COMELEC arose from a dispute over the mayoralty candidacy in Santiago City, Isabela, during the 2022 National and Local Elections. Amelita Navarro initially filed her Certificate of Candidacy (COC) as the official nominee of Partido Reporma. Later, Christopher Ayson also filed a COC, claiming the same party’s endorsement. This led Senator Panfilo Lacson, the chairman of Partido Reporma, to send letters to COMELEC disavowing Ayson’s nomination and affirming Navarro as the party’s official candidate. Navarro subsequently withdrew her candidacy, and Giorgidi Aggabao sought to substitute her. However, COMELEC declared both Navarro and Ayson as independent candidates due to the double nomination, thus disqualifying Aggabao’s substitution. Aggabao and Navarro then filed a petition arguing that COMELEC failed to properly investigate the matter and violated their right to due process.

The Supreme Court addressed the COMELEC’s powers, categorizing them into administrative, quasi-legislative, and quasi-judicial. Administrative functions involve enforcing and administering election laws. Quasi-legislative functions pertain to issuing rules and regulations. Quasi-judicial functions concern resolving controversies arising from the enforcement of election laws. The Court clarified that while COMELEC has a ministerial duty to receive COCs and Certificates of Nomination and Acceptance (CONAs) filed in due form, this duty does not preclude the agency from exercising its quasi-judicial powers when controversies arise. In this case, the controversy arose when Senator Lacson challenged the authenticity of Ayson’s CONA.

The Court emphasized that when Senator Lacson sent his letters challenging the validity of Ayson’s CONA, it triggered the COMELEC’s duty to exercise its quasi-judicial functions. This required COMELEC to investigate, conduct hearings, weigh evidence, and draw conclusions based on those facts. As the court noted in Francisco v. COMELEC:

The COMELEC’s adjudicative function over election contests is quasi-judicial in character since the COMELEC is a governmental body, other than a court, that is vested with jurisdiction to decide the specific class of controversies it is charged with resolving. In adjudicating the rights of persons before it, the COMELEC is not just empowered but is in fact required to investigate facts or ascertain the existence of facts, hold hearings, weigh evidence, and draw conclusions from them as basis for their official action and exercise of discretion in a judicial nature.

The COMELEC’s failure to conduct a hearing and resolve the conflicting claims constituted a grave abuse of discretion. Grave abuse of discretion is defined as an arbitrary or despotic exercise of power due to passion, prejudice, or personal hostility, or a whimsical, arbitrary, or capricious exercise of power that amounts to an evasion or refusal to perform a positive duty enjoined by law. The Court referenced the principle that all election cases, including pre-proclamation controversies, must be decided by COMELEC in Division, with motions for reconsideration decided by the COMELEC En Banc, per Section 3 of Article IX-C of the Constitution.

The ruling underscores that the absence of specific rules addressing conflicting CONAs does not justify COMELEC’s inaction. It was incumbent upon COMELEC to initiate a summary hearing to ascertain which candidate was the legitimate nominee of Partido Reporma. This is based on the principle that due process requires notice and hearing in every adjudication made in the exercise of quasi-judicial functions. The COMELEC’s reliance solely on the recommendation of its Law Department, without conducting its own independent confirmation, was a critical failure.

Associate Justice Alfredo Benjamin S. Caguioa, in his concurring opinion, further clarified the distinction between the COMELEC’s administrative and quasi-judicial roles. The administrative role involves applying policies and enforcing orders, while the quasi-judicial role requires investigating facts, weighing evidence, and drawing conclusions. Justice Caguioa argued that when Senator Lacson challenged Ayson’s CONA, it created a legal controversy necessitating the exercise of COMELEC’s quasi-judicial powers. The COMELEC should have endorsed the matter to one of its divisions for hearing despite the seeming vacuum in its rules treating of a remedy to challenge its administrative allowance or disallowance of substitutions.

The Court also addressed COMELEC’s explanation for proceeding with printing ballots despite the TRO issued by the Court. COMELEC cited its strict timeline for election preparations and the technical impossibility of complying with the TRO after January 9, 2022, the date of the final ballot face generation. The Court accepted this explanation, recognizing COMELEC’s expertise and constitutional mandate to conduct elections promptly. However, the core ruling of the case underscores the necessity of following due process in the future by properly adjudicating conflicts before those deadlines approach. As the court noted, in another recent case, Marquez v. COMELEC, it is vital for the COMELEC to promptly resolve substitution cases and similar cases which may result in the inclusion or exclusion of candidates.

This ruling has significant implications for future elections. The COMELEC is now strongly urged to adopt a practicable plan and timeline to ensure that all cases involving substitution or inclusion/exclusion of candidates are resolved at the earliest possible time. It emphasizes that election cases must be decided promptly to prevent them from becoming moot. The COMELEC must balance its need for efficiency with the constitutional imperative to ensure due process and fairness in election proceedings. Political parties are also enjoined to be more circumspect in issuing CONAs.

FAQs

What was the key issue in this case?	The key issue was whether COMELEC gravely abused its discretion by failing to conduct a hearing to resolve conflicting claims regarding party endorsements for mayoralty candidates in Santiago City.
What did the Supreme Court rule?	The Supreme Court ruled that COMELEC committed grave abuse of discretion and nullified its resolutions denying Giorgidi Aggabao’s substitution as a candidate due to the agency’s failure to properly investigate the conflicting claims.
What are COMELEC’s main powers in election cases?	COMELEC has administrative, quasi-legislative, and quasi-judicial powers. The quasi-judicial power requires COMELEC to investigate facts, hold hearings, weigh evidence, and draw conclusions from them as a basis for official action.
What is a Certificate of Nomination and Acceptance (CONA)?	A CONA is a document issued by a political party certifying that a particular individual is the party’s official candidate for a specific elective position. It signifies the party’s endorsement and support for the candidate.
What happens when a political party nominates multiple candidates for the same position?	According to COMELEC rules, if a political party nominates more than the allowed number of candidates for a position, all those candidates may be declared independent, losing their status as official party nominees.
What is grave abuse of discretion?	Grave abuse of discretion means exercising power in an arbitrary or despotic manner due to passion, prejudice, or personal hostility. It also includes a whimsical or capricious exercise of power that disregards legal duties.
Why was COMELEC’s decision considered a grave abuse of discretion in this case?	COMELEC’s decision was considered a grave abuse of discretion because the agency failed to conduct a hearing and investigate the conflicting claims regarding the authenticity of the CONAs, thereby denying due process to the candidates.
What is the practical implication of this ruling for future elections?	The ruling emphasizes the importance of COMELEC conducting thorough investigations and hearings when disputes arise over party endorsements to ensure due process and fair elections.
Can a political party nominate a non-member as a candidate?	Yes, a political party can nominate and support candidates who are not members of the party, known as guest candidates, in accordance with election laws.

The Supreme Court’s decision in Aggabao v. COMELEC serves as a crucial reminder of the importance of due process and the right to a hearing in election-related disputes. It also clarifies the COMELEC’s duty to exercise its quasi-judicial functions when controversies arise, ensuring fairness and transparency in the electoral process. The COMELEC’s failure to properly investigate and adjudicate conflicting candidacy claims deprived the involved candidates of their right to due process. In the future, this should make election bodies more careful with election process.

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: GIORGIDI B. AGGABAO AND AMELITA S. NAVARRO, PETITIONERS, VS. COMMISSION ON ELECTIONS (COMELEC) AND LAW DEPARTMENT, RESPONDENTS., G.R. No. 258456, July 26, 2022