Saura v. Sindico
REITERATIONFacts
The Antecedents: Ramon E. Saura and Estela P. Sindico were aspirants for nomination as the official candidate of the Nacionalista Party for Congress in the fourth district of Pangasinan. On August 23, 1957, they entered into a written agreement wherein each pledged not to run as a rebel or independent candidate after losing in the party convention. Procedural History: In the provincial convention held on August 31, 1957, Saura was proclaimed the official candidate. Despite this, Sindico filed her certificate of candidacy on September 6, 1957, and actively campaigned. Saura filed a suit for damages on October 5, 1957. The Court of First Instance dismissed the complaint, holding the agreement null and void because a public office is not within the commerce of man and the pledge curtailed the free exercise of the elective franchise. The Petition: Plaintiff-appellant Saura appealed the dismissal order, arguing the validity of the agreement.
Issue(s)
Whether the agreement between aspirants for nomination to a public office, pledging not to run as independent or rebel candidates after losing in the convention, is valid. Whether a public office is considered within the "commerce of man" for contractual purposes.
Ruling
The Supreme Court affirmed the order of dismissal, holding that the agreement is null and void.
Ratio Decidendi
On the validity of the agreement and the nature of public office: The Court held that the agreement between Saura and Sindico is null and void. The subject matter of the contract, being a public office, is not within the commerce of man. Political rights conferred upon citizens, including the right to present one's candidacy to the people and to be voted into public office, are conferred not for individual or private benefit but for the public good and interest, and thus cannot be bargained away or curtailed with impunity. Such rights are excluded from the commerce of man by law and public policy. The qualifications for public office are fixed by constitutional and statutory provisions and cannot be enlarged or reduced by mere agreements between private parties. On the curtailment of the elective franchise: The Court further found that the "pledge" in the agreement was in curtailment of the free exercise of the elective franchise, which is against public policy. Every voter has the right to be a candidate if they possess the legal qualifications, and this right cannot be limited. While a voter may not necessarily be the candidate of a particular political party, they can still be a candidate at the general election by petition. The right of a voter to vote for whomever they please cannot be limited by such agreements. In common law, agreements in consideration of the withdrawal of candidates for office have been condemned as against public policy.
Main Doctrine
An agreement between aspirants for nomination to a public office, wherein they pledge not to run as rebel or independent candidates after losing in the convention, is null and void as it is contrary to public policy, the subject matter being a public office which is not within the commerce of man and the pledge curtailing the free exercise of the elective franchise.