Santos v. Commission on Elections
REITERATIONFacts
The Antecedents: Petitioner Manuel I. Santos was disqualified by the Commission on Elections (COMELEC) from running as a candidate for Mayor of Taytay, Rizal, on the ground of 'political turncoatism' and violation of Presidential Decree No. 1661 against 'guest candidates.' The disqualification stemmed from Santos' alleged change of political party affiliation from Kilusang Bagong Lipunan (KBL) to the Nacionalista Party (NP) within the prohibited period before an election. Procedural History: A petition for disqualification was filed against petitioner Santos by private respondents. The COMELEC, in its Resolution dated January 19, 1980, found that Santos had resigned from his position as a member of the KBL Municipal Committee and subsequently became an official candidate of the NP. This action was deemed a violation of Section 10, Article XII(C) of the Constitution and PD 1661, as amended. The COMELEC's resolution disqualified Santos. The Petition: Petitioner invoked the Supreme Court's power to review COMELEC decisions via certiorari, arguing that the resolution was not supported by substantial evidence and that his right to due process was violated. He contended that KBL was merely an umbrella organization and not a political party, thus his affiliation with it did not constitute a change of political party.
Issue(s)
Whether the COMELEC resolution disqualifying petitioner Santos is supported by substantial evidence. Whether petitioner Santos was denied due process. Whether KBL was a political party distinct from the NP. Whether Presidential Decree No. 1661, as amended, was correctly applied to petitioner's case.
Ruling
The Supreme Court dismissed the petition and affirmed the COMELEC's Resolution dated January 19, 1980, allowing it to stand with all its legal effects.
Ratio Decidendi
On the issue of substantial evidence supporting the COMELEC resolution: The Court found substantial evidence to support the COMELEC's conclusion that petitioner Santos was disqualified from running as an NP candidate for Mayor of Taytay, Rizal, due to violation of the constitutional prohibition against 'turncoatism' and PD 1661. The evidence showed that Santos resigned from his position in the KBL Municipal Committee and was subsequently nominated by the NP. The Court noted the striking similarity of the facts to those in Evasco vs. COMELEC and Gabatan vs. COMELEC, where similar disqualifications were upheld. The Court reasoned that the act of resigning from the KBL, where he was an active member, indicated that he considered KBL a distinct political aggrupation from the NP. The COMELEC's accreditation of KBL separately from NP in the 1978 elections further solidified its status as a political party. On the issue of denial of due process: The Court perceived no sign of complaint regarding the sufficiency of notice and hearing. It noted that the evidence petitioner wished to present was admitted by the COMELEC for evaluation. The Court stated that the only question presented was whether the COMELEC resolution was supported by substantial evidence, which it found to be the case. Therefore, no violation of procedural due process occurred. On the issue of KBL being a political party: The Court concluded that KBL had always been a political party, distinct and separate from the NP. This was supported by the COMELEC's Resolution No. 1406, which accredited KBL separately from NP for the April 7, 1978 election. The Court reasoned that if KBL were not a political party, block voting, as declared valid in Peralta vs. COMELEC, could not have been availed of by it. The active involvement of petitioner in KBL's political affairs as a party member of its Municipal Committee was a decisive consideration in finding 'turncoatism.' On the issue of the applicability of PD 1661: The Court held that PD 1661, being an implementation of the constitutional provision against 'turncoatism,' was correctly applied. The Court rejected petitioner's argument that the decree, if applied to him, would be an ex post facto law. It reiterated its ruling in Evasco and Gabatan that the decree does not have retrospective effect and does not fall under the prohibition against ex post facto laws because it provides for a disqualification from an elective office, which is a privilege and not a criminal matter. The Court emphasized that the constitutional provision against 'political turncoatism' is mandatory and applies to all elections held under its regime.
Main Doctrine
The Supreme Court affirmed the Commission on Elections' (COMELEC) resolution disqualifying a candidate for Mayor due to 'political turncoatism' and violation of PD 1661, finding substantial evidence to support the COMELEC's findings and no grave abuse of discretion or denial of due process.