CASE DIGEST
Partido Demokratiko
Pilipino-Lakas ng Bayan v. Commission on Elections
G.R. No. 225152,
[October 5, 2021]
EN BANC, LOPEZ, M.V
Election Law; Constitutionality of COMELEC resolution extending deadline submission of SOCE
The Supreme Court En banc says the
COMELEC committed grave abuse of discretion when it extended the deadline of submission
of the Statements of Contributions and Expenditures (SOCE) beyond the 30-day period
mandated by RA 7166 or the Synchronized Elections Law. The COMELEC has exceeded
its delegated rule making authority which amounts to usurpation of legislative
power.
A Petition for certiorari was filed by Partido Demokratiko Pilipino–Lakas ng Bayan (PDP-Laban) against the COMELEC. PDP-Laban challenged the COMELEC’S Resolution No. 10147, which extended the filing of Statements of Contributions and Expenditures (SOCE) until June 30, 2016, despite being originally set at June 8,2016 which is thirty (30) days after the May 9, 2016 national elections. PDP-Laban argued that the COMELEC exceeded its limits and violated section 14 of RA 7166 due to the said order.
Whether or not the Commission on Elections Resolution No. 10147 which extended the SOCE submission after the 2016 elections is unconstitutional.
YES. The Supreme Court (SC) ruled that the
Commission on Elections (COMELEC) cannot extend the deadline for submission by
candidates of their Statements of Contributions and Expenditures (SOCE). Under
section 14 of Republic Act No. 7166 or the Synchronized
Elections Law, candidates are required to file their full, true and
itemized statement of all contributions and expenditures in connection with the
election within 30 days after the conduct of election. The language in RA 7166,
Section 14 is not ambiguous; the law is clear that SOCEs must be filed within
30 days after the latest polls. Thus, the COMELEC committed grave abuse of
discretion when it extended the SOCE deadline and exempted candidates and
political parties from administrative liabilities in violation of the clear
language of the law and legislative intent. The COMELEC likewise cannot
conveniently invoke the exigency of public service to justify its actions. The
COMELEC’s task is to administer the law, not supplant them. For these reasons,
the Commission on Elections Resolution No. 10147 is declared void for being
repugnant to the law. Applying the doctrine of operative fact, however, the
effect of the declaration of unconstitutionality of the COMELEC’s Resolution
shall be applied prospectively. Thus, the Statements of Contributions and
Expenditures for the May 9, 2016 national and local elections that were
submitted within the extended period (on or before June 30, 2016) are deemed
timely filed.
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