Legaspi v. Commission on Elections
REVERSALFacts
The Antecedents: Petitioner Feliciano Legaspi and private respondent Alfredo D. Germar were candidates for mayor, and private respondent Rogelio Santos, Jr. was a candidate for councilor, in Norzagaray, Bulacan, during the May 13, 2013 elections. Legaspi filed a Petition for Disqualification against Germar and Santos, alleging that they engaged in massive vote-buying from May 11, 2013, until election day. The alleged vote-buying involved political leaders distributing envelopes containing Php 500.00 each and sample ballots of the respondents to voters. The distribution was reportedly occurring inside an office at North Hills Village, which was subsequently padlocked. Evidence of vote-buying, including undistributed envelopes containing approximately Php 800,000.00 and sample ballots, was allegedly intercepted by citizens as police attempted to retrieve it. Procedural History: The COMELEC Special First Division, by a 2-1 vote on October 3, 2013, disqualified Germar and Santos and referred the criminal aspect to the Law Department. The private respondents moved for reconsideration before the COMELEC en banc. On July 10, 2014, the COMELEC en banc denied the motion for reconsideration with a 3-2-1-1 vote. Due to the lack of the required four votes, a re-deliberation was conducted, resulting in an Order dated January 28, 2015, which dismissed the Petition for Disqualification with a 3-2-2 vote. Petitioner Legaspi then filed a Rule 64 petition before the Supreme Court, which was initially dismissed on September 1, 2015. Legaspi filed the instant motion for reconsideration. The Petition: Petitioner Legaspi, through a motion for reconsideration, assails the Supreme Court's September 1, 2015 Decision that dismissed his Rule 64 petition. The core issue is the interpretation of Section 6, Rule 18 of the COMELEC Rules of Procedure concerning the effects of the COMELEC en banc's failure to reach the necessary majority vote. Legaspi argues that the COMELEC en banc's dismissal of his disqualification case, despite the Special First Division's ruling in his favor and the fact that only two commissioners voted to grant the reconsideration, was erroneous. He contends that the COMELEC en banc's failure to secure four votes should have affirmed the division's decision, not dismissed his petition. The petition seeks to reverse the Court's prior ruling and reinstate the COMELEC Special First Division's decision disqualifying the respondents.
Issue(s)
Whether the COMELEC en banc's dismissal of the Petition for Disqualification, based on a failure to obtain the necessary majority votes after re-deliberation, was proper. Whether the interpretation of Section 6, Rule 18 of the COMELEC Rules of Procedure in the case of Mendoza v. COMELEC and the Court's September 1, 2015 Decision is constitutional; and whether Section 6, Rule 18 was properly applied.
Ruling
The Supreme Court GRANTED the motion for reconsideration, REVERSED and SET ASIDE its September 1, 2015 Decision, and GRANTED the petition. The January 28, 2015 Order of the COMELEC en banc was SET ASIDE, and the October 3, 2013 Resolution of the COMELEC Special First Division was REINSTATED and AFFIRMED. The decision is immediately executory.
Ratio Decidendi
On whether the COMELEC en banc's dismissal of the Petition for Disqualification was proper: The Court held that the interpretation of Section 6, Rule 18 of the COMELEC Rules of Procedure in Mendoza v. COMELEC and the September 1, 2015 Decision suffers from constitutional infirmities. The Court clarified that the effects of the COMELEC en banc's failure to decide depend on the type of case or matter before it. In this case, the pending matter before the COMELEC en banc was a motion for reconsideration, which is an "incidental matter." Applying the third effect of Section 6, Rule 18, "all incidental matters, the petition or motion shall be denied." This interpretation is consistent with Section 7, Rule 56 of the Rules of Court and A.M. No. 99-1-09-SC, which state that a motion for reconsideration is an incidental matter and is deemed denied if no majority vote is reached. The failure to obtain the required four votes to grant the motion for reconsideration means the motion is defeated, and the prior ruling of the COMELEC division subsists and is affirmed. On the interpretation of Section 6, Rule 18 of the COMELEC Rules of Procedure and its proper application: The Court found that the September 1, 2015 Decision erred in applying the first effect of Section 6, Rule 18, which pertains to actions "originally commenced in the Commission." The Court reasoned that the matter pending before the COMELEC en banc was not the original Petition for Disqualification but the motion for reconsideration filed by the private respondents. A motion for reconsideration is not an "action or proceeding" within the contemplation of Part V of the COMELEC Rules of Procedure. Furthermore, the second effect, which applies to "appealed cases," was also inapplicable because a motion for reconsideration is not an appeal. Therefore, only the third effect, concerning "incidental matters," was applicable, leading to the denial of the motion for reconsideration.
Main Doctrine
A motion for reconsideration before the COMELEC en banc is an incidental matter. If the necessary majority vote cannot be obtained to grant the motion, it is deemed denied, and the prior ruling of the COMELEC division stands affirmed. This interpretation harmonizes Section 6, Rule 18 of the COMELEC Rules of Procedure with Section 7, Rule 56 of the Rules of Court and A.M. No. 99-1-09-SC.