Salvador v. Commission on Elections
REITERATIONFacts
The Antecedents: Petitioner Mario O. Salvador (Salvador) was a mayoralty candidate in San Jose City, Nueva Ecija in the 2010 elections. Private respondent Alexander Belena (Belena) filed a Complaint-Affidavit against Salvador for alleged violation of Section 100 in relation to Section 262 of the Omnibus Election Code (OEC), as amended by Section 13 of Republic Act (R.A.) No. 7166, for overspending. Procedural History: Belena alleged that Salvador's Statement of Election Contribution and Expenditure (SOCE) showed a total spending of P449,000.00, exceeding the P275,667.00 limit allowed for a candidate of his stature (P3.00 per registered voter, as Salvador was a member of a political party). Salvador contended that he did not receive support from any political party, thus the P5.00 per voter exception under Section 13 of R.A. No. 7166 should apply. The Commission on Elections (COMELEC) En Banc, in a Resolution dated November 2, 2015, found probable cause and directed the filing of an information against Salvador, interpreting the law strictly and applying the verba legis principle. Salvador's Motion for Reconsideration was denied in a Resolution dated March 8, 2017. The Petition: Salvador filed a Petition for Certiorari under Rule 64, challenging the COMELEC En Banc's Resolutions, alleging grave abuse of discretion.
Issue(s)
Whether the interpretation of Section 13 of R.A. No. 7166 by the COMELEC En Banc, which requires a candidate to be both without a political party and without support from any political party to avail of the P5.00 per voter expenditure limit, is correct. Whether the COMELEC En Banc committed grave abuse of discretion amounting to lack or in excess of jurisdiction when it recommended the filing of an appropriate information against Salvador for violation of election spending limits.
Ruling
The Supreme Court ruled in the negative, denying the petition and affirming the Resolutions of the COMELEC En Banc. The Court held that the COMELEC did not commit grave abuse of discretion.
Ratio Decidendi
On the interpretation of Section 13 of R.A. No. 7166: The Court affirmed the COMELEC's interpretation that the word "and" in the proviso "Provided, That a candidate without any political party and without support from any political party may be allowed to spend Five Pesos (P5.00) for every such voter" is conjunctive. This means that for a candidate to be allowed to spend P5.00 per registered voter, they must satisfy both conditions: being without any political party and being without support from any political party. The Court emphasized the principle of verba legis, stating that the law is clear and free from ambiguity, and its plain meaning should be followed. The Court reasoned that the legislature intended to ensure equality among aspirants, recognizing the political advantages enjoyed by candidates who are members of political parties, such as machinery, goodwill, representation, and resources. These advantages are not enjoyed by independent candidates, hence the need to afford them equal chances. The Court further clarified that "support" is not limited to financial aid but includes the machinery and resources of a political party. Therefore, Salvador, being a member of a political party, was only entitled to the P3.00 per voter limit, not the P5.00 limit. On the alleged overspending and grave abuse of discretion: The Court found that it was undisputed that the number of registered voters in San Jose City, Nueva Ecija was 91,889. Based on the P3.00 per voter limit applicable to Salvador, the maximum allowable expenditure was P275,667.00. Salvador's declared spending of P449,000.00, as per his SOCE, clearly exceeded this limit. This constituted an election offense under Section 262 in relation to Section 263 of the OEC. Consequently, the COMELEC En Banc did not commit grave abuse of discretion in ordering the filing of an information against Salvador.
Main Doctrine
A candidate is allowed to spend P5.00 for every registered voter only if the candidate is both without any political party and without support from any political party. The word 'and' in Section 13 of R.A. No. 7166 is conjunctive, meaning both conditions must be met for the higher expenditure limit to apply. Otherwise, the P3.00 cap applies.