Maruhom v. Commission on Elections
REITERATIONFacts
The Antecedents: Petitioner Jamela Salic Maruhom and private respondent Mohammadali Abinal were mayoralty candidates in Marantao, Lanao del Sur, for the May 14, 2007 elections. Abinal filed a petition to disqualify Maruhom, alleging she was a double registrant, having registered in Marawi City on July 26, 2003, and in Marantao on July 29, 2003, without canceling the prior registration. Abinal also claimed Maruhom made false material representations in her voter registrations and Certificate of Candidacy (COC) regarding her name, birth date, birthplace, and residency. Procedural History: The COMELEC First Division granted Abinal's petition, declaring Maruhom's Marantao registration void ab initio and ordering the deletion of her name from the list of candidates. The COMELEC En Banc denied Maruhom's motion for reconsideration, affirming the First Division's resolution and referring the case for investigation of election offenses. Meanwhile, the elections proceeded, and Abinal won and was proclaimed mayor. The Petition: Maruhom filed a Petition for Certiorari with the Supreme Court, assailing the COMELEC resolutions and imputing grave abuse of discretion, primarily arguing that the COMELEC lacked jurisdiction to declare her voter registration void and that she was not a double registrant.
Issue(s)
Whether the Commission on Elections (COMELEC) has jurisdiction to declare a voter registration void in a petition for disqualification and cancellation of Certificate of Candidacy (COC). Whether petitioner Jamela Salic Maruhom committed double registration and made false material representations in her COC, warranting its cancellation.
Ruling
The Petition for Certiorari is dismissed. The Resolution dated May 8, 2007, of the COMELEC First Division and the Resolution dated August 21, 2007, of the COMELEC En Banc in SPA No. 07-093 are affirmed in toto.
Ratio Decidendi
On the COMELEC's Jurisdiction: The Supreme Court held that the COMELEC has jurisdiction over petitions filed under Section 78 of the Omnibus Election Code (OEC), which allows for the denial or cancellation of a COC due to false material representations. While Section 33 of Republic Act No. 8189 (Voter's Registration Act) grants MTCs jurisdiction over inclusion and exclusion of voters, this does not divest the COMELEC of its power to determine the validity of a voter registration when it directly affects a candidate's eligibility and is raised in a petition to cancel a COC. The Court clarified that the COMELEC's determination in this context does not deprive a person of their right to vote but rather addresses their eligibility to run for a specific office based on the representations made in their COC. The COMELEC's "broad plenary powers to enforce and administer all laws relating to election" also support its competence in this matter. On Double Registration and False Material Representations: The Court found that Maruhom was indeed a double registrant. She registered in Marawi on July 26, 2003, and then again in Marantao on July 29, 2003, without canceling her Marawi registration. Pursuant to COMELEC Minute Resolution No. 00-15, subsequent registrations are void ab initio if the prior registration subsists. Therefore, Maruhom's Marantao registration was void, making her not a registered voter in Marantao. This constituted a false material representation in her COC, as she declared herself a registered voter in Marantao and eligible to run for mayor. The Court noted that Maruhom's attempt to cancel her Marawi registration shortly before filing her COC indicated a deliberate attempt to conceal her prior registration and mislead the electorate regarding her qualifications.
Main Doctrine
A false representation of a material fact in a Certificate of Candidacy (COC), which affects a candidate's eligibility or qualification, is a ground for denial or cancellation of the COC under Section 78 of the Omnibus Election Code. Such false representation must be deliberate and intended to deceive the electorate.