Pilar v. Commission on Elections
NEW DOCTRINEFacts
The Antecedents: Petitioner Juanito C. Pilar filed his certificate of candidacy for Member of the Sangguniang Panlalawigan of Isabela on March 22, 1992. Three days later, on March 25, 1992, he withdrew his certificate of candidacy. Procedural History: The Commission on Elections (COMELEC) imposed a fine of P10,000.00 on petitioner for failure to file his statement of contributions and expenditures. The COMELEC denied his motion for reconsideration and later denied his petition before the COMELEC En Banc. The Petition: Petitioner filed a petition for certiorari with the Supreme Court, assailing the Resolution of the COMELEC En Banc.
Issue(s)
Whether a candidate who withdraws their certificate of candidacy is still considered a "candidate" under R.A. No. 7166 for the purpose of filing a statement of contributions and expenditures. Whether the COMELEC committed grave abuse of discretion in imposing a fine on the petitioner for failure to file the said statement, considering the candidate withdrew their candidacy.
Ruling
The petition is DISMISSED. The COMELEC did not commit grave abuse of discretion.
Ratio Decidendi
On the issue of whether a withdrawn candidate is still considered a "candidate" under R.A. No. 7166: The Court held that Section 14 of R.A. No. 7166 obligates "every candidate" to file a statement of contributions and expenditures. The Court applied the legal principle that where the law does not distinguish, courts should not distinguish (Ubi lex non distinguit nec nos distinguere debemos). Therefore, the term "every candidate" must be interpreted to include not only those who pursued their campaign but also those who withdrew their candidacies. The COMELEC, in implementing R.A. No. 7166 through Resolution No. 2348, also categorically referred to "all candidates who filed their certificates of candidacy." The use of the word "shall" in the law indicates a mandatory duty. The state has a vital interest in ensuring a clean electoral process, and regulating contributions and expenditures is a means to achieve this. The law aims to compel publicity regarding campaign finances to prevent improper use of money and to enable voters to evaluate influences on candidates. The Court noted that it is not improbable for a candidate who withdrew to have accepted contributions or incurred expenditures, even during a short campaign period. Furthermore, Resolution No. 2348 even requires candidates who received no contributions or made no expenditures to file a statement reflecting such fact. Lastly, the Court pointed out that under Section 73 of the Omnibus Election Code, the filing or withdrawal of a certificate of candidacy does not extinguish any civil, criminal, or administrative liability incurred by the candidate. On the issue of whether the COMELEC committed grave abuse of discretion: The Court found that the COMELEC did not commit grave abuse of discretion. By ruling that a candidate who withdrew their certificate of candidacy is still considered a "candidate" under R.A. No. 7166 for the purpose of filing a statement of contributions and expenditures, the Court effectively upheld the COMELEC's decision to impose the fine. The petition for certiorari, which challenged the COMELEC's resolution, was therefore dismissed.
Main Doctrine
A candidate who withdraws their certificate of candidacy is still considered a "candidate" under R.A. No. 7166 and is therefore obligated to file a statement of contributions and expenditures, as the law makes no distinction between a candidate who pursued their campaign and one who withdrew.