Teves v. Commission on Elections
REITERATIONFacts
The Antecedents: Petitioner Edgar Y. Teves was a candidate for Representative of the 3rd legislative district of Negros Oriental in the May 14, 2007 elections. Respondent Herminio G. Teves filed a petition to disqualify petitioner, alleging that petitioner was convicted in Teves v. Sandiganbayan for violating Section 3(h) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act) for possessing a financial interest in a cockpit, prohibited under Section 89(2) of the Local Government Code (LGC) of 1991. This conviction carried a fine of P10,000.00 and, according to respondent, involved moral turpitude, thus disqualifying petitioner from public office. Procedural History: The Commission on Elections (COMELEC) First Division disqualified petitioner and ordered the cancellation of his Certificate of Candidacy. Petitioner moved for reconsideration, but the COMELEC en banc denied it, deeming the motion moot and academic because petitioner had lost in the elections. The COMELEC en banc, in effect, affirmed the First Division's ruling that the conviction involved moral turpitude. The Petition: Petitioner filed a petition with the Supreme Court, arguing that the COMELEC en banc committed grave abuse of discretion by not resolving the main issue of moral turpitude, which he contended would affect his qualification for future elections. He also argued that his conviction did not involve moral turpitude, contrary to the COMELEC's findings.
Issue(s)
Whether the COMELEC en banc committed grave abuse of discretion in declaring the disqualification case moot and academic without resolving the issue of moral turpitude, considering the impact on future eligibility for public office and the timing of the disqualification period. Whether the crime for which petitioner Edgar Y. Teves was convicted, specifically the violation of Section 3(h) of R.A. No. 3019 for possessing a financial interest in a cockpit prohibited by Section 89(2) of the LGC of 1991, involves moral turpitude, considering the nature of the crime, the specific facts of the case, and the intent of the petitioner.
Ruling
The Supreme Court granted the petition, reversed and set aside the COMELEC Resolutions, and declared that the crime committed by petitioner did not involve moral turpitude. Consequently, petitioner was not disqualified on this ground.
Ratio Decidendi
On the issue of mootness and the COMELEC's discretion: The Court held that the fact that petitioner lost in the election did not render the issue of his disqualification moot and academic. The question of whether he was convicted of a crime involving moral turpitude remained a justiciable issue that the COMELEC should have resolved, as it impacts his eligibility for future public office. The COMELEC's act of declaring the case moot without addressing the core issue constituted grave abuse of discretion. The Court also noted that the five-year disqualification period, if applicable, would not have ended by the time of the May 14, 2010 elections, as the fine was paid on May 24, 2005, meaning the disqualification would end on May 25, 2010. On whether the conviction involved moral turpitude: The Court reiterated the definition of moral turpitude as encompassing acts contrary to justice, modesty, or good morals, implying inherent immorality rather than mere prohibition. It distinguished between mala in se and mala prohibita crimes, noting that while mala in se generally involve moral turpitude, this is not always clear-cut, and the determination ultimately depends on the facts and circumstances. The Court found that petitioner's conviction under the second mode of Section 3(h) of R.A. 3019 (possession of a prohibited interest) did not automatically involve moral turpitude. The Court examined the specific facts, noting that petitioner owned the cockpit before the prohibition took effect under the LGC of 1991. The transfer of management to his wife occurred before the LGC of 1991, and his ownership predated the prohibition. The Court also considered that the penalty imposed was a fine, which, coupled with the finding that petitioner was likely unaware of the prohibition shortly after its enactment, indicated that the violation was not intentionally done contrary to good morals but due to ignorance. The Court emphasized that while cockfighting is a form of gambling, its morality or the wisdom of its legalization is not a justiciable issue, and its prohibition under the LGC does not inherently make the act immoral.
Main Doctrine
Conviction for violation of Section 3(h) of R.A. 3019, specifically the possession of a prohibited financial interest in a cockpit under Section 89(2) of the Local Government Code of 1991, does not automatically involve moral turpitude. A determination of all surrounding circumstances is necessary, and acts that are merely mala prohibita, without being inherently immoral, do not involve moral turpitude.