Court junks Comelec DQ in 2 cases
THE Supreme Court has reversed a Commission on Elections (Comelec) resolution disqualifying a substitute candidate for vice mayor of Limay, Bataan, in the 2025 midterm elections. On Wednesday, the court ruled in favor of Marie Grace David, reversing the Comelec resolution that disqualified her from running for vice mayor of Limay, Bataan. The election body had earlier rejected her certificate of candidacy (COC), citing her failure to meet the deadline for substitution. The case arose when Richie Jason David withdrew his candidacy for vice mayor on Dec. 6, 2024. Following her nomination under the Partido Federal ng Pilipinas, David promptly filed her COC, along with her Certificate of Nomination and Acceptance. She also petitioned for her inclusion in the official list of candidates. However, the Comelec denied her substitution, arguing that she failed to submit her documents within the prescribed period set under Section 59 of Comelec Resolution 11045, which established Oct. 8, 2024, as the final deadline for substitutions due to candidate withdrawals. David elevated her case to the Supreme Court, and on Jan. 14, the tribunal issued a temporary restraining order preventing the Comelec from implementing its resolution. In its final ruling, the court found that the Comelec had committed grave abuse of discretion in rejecting David's candidacy. The high court determined that she had fully complied with the requirements of Section 77 of the Omnibus Election Code, affirming her as a bona fide candidate for the vice mayor position. The court subsequently barred the Comelec en banc from enforcing its disputed resolution. In a separate ruling, the tribunal also granted the petition of Chito Bulatao Balintay, an indigenous leader from Zambales, overturning Comelec's decision to disqualify his gubernatorial bid due to an incomplete COC submission. Balintay filed his COC on the last day of filing, just 25 minutes before the 5 p.m. deadline. However, his submission lacked a required fifth copy and documentary stamps. Despite being advised to complete the missing documents, he was unable to do so before the deadline elapsed in three minutes. Under Section 37 of Comelec Resolution 11045, incomplete COCs are neither accepted nor stamped as received, even if submitted before the deadline. The Comelec, citing strict adherence to the rules, rejected Balintay's candidacy. However, the court ruled that the Comelec had gravely abused its discretion by rigidly applying technical rules in a manner that denied a candidate a fair chance to run for office. The court emphasized that elections are dynamic events, and the Comelec must be prepared to make reasonable accommodations in the interest of justice and fair play. "The elections are not conducted under laboratory conditions. The Comelec must ensure that its rules do not become instruments of injustice that disenfranchise willing candidates and, in turn, the electorate," the court said. With this ruling, the court ordered Comelec to accept Balintay's COC and include his name in the official list of candidates for Zambales governor in the 2025 elections.
Tomas Kauer - Moderator 
THE Supreme Court has reversed a Commission on Elections (Comelec) resolution disqualifying a substitute candidate for vice mayor of Limay, Bataan, in the 2025 midterm elections.
On Wednesday, the court ruled in favor of Marie Grace David, reversing the Comelec resolution that disqualified her from running for vice mayor of Limay, Bataan. The election body had earlier rejected her certificate of candidacy (COC), citing her failure to meet the deadline for substitution.
The case arose when Richie Jason David withdrew his candidacy for vice mayor on Dec. 6, 2024. Following her nomination under the Partido Federal ng Pilipinas, David promptly filed her COC, along with her Certificate of Nomination and Acceptance. She also petitioned for her inclusion in the official list of candidates.
However, the Comelec denied her substitution, arguing that she failed to submit her documents within the prescribed period set under Section 59 of Comelec Resolution 11045, which established Oct. 8, 2024, as the final deadline for substitutions due to candidate withdrawals.
David elevated her case to the Supreme Court, and on Jan. 14, the tribunal issued a temporary restraining order preventing the Comelec from implementing its resolution.
In its final ruling, the court found that the Comelec had committed grave abuse of discretion in rejecting David's candidacy. The high court determined that she had fully complied with the requirements of Section 77 of the Omnibus Election Code, affirming her as a bona fide candidate for the vice mayor position. The court subsequently barred the Comelec en banc from enforcing its disputed resolution.
In a separate ruling, the tribunal also granted the petition of Chito Bulatao Balintay, an indigenous leader from Zambales, overturning Comelec's decision to disqualify his gubernatorial bid due to an incomplete COC submission.
Balintay filed his COC on the last day of filing, just 25 minutes before the 5 p.m. deadline. However, his submission lacked a required fifth copy and documentary stamps. Despite being advised to complete the missing documents, he was unable to do so before the deadline elapsed in three minutes.
Under Section 37 of Comelec Resolution 11045, incomplete COCs are neither accepted nor stamped as received, even if submitted before the deadline. The Comelec, citing strict adherence to the rules, rejected Balintay's candidacy.
However, the court ruled that the Comelec had gravely abused its discretion by rigidly applying technical rules in a manner that denied a candidate a fair chance to run for office. The court emphasized that elections are dynamic events, and the Comelec must be prepared to make reasonable accommodations in the interest of justice and fair play.
"The elections are not conducted under laboratory conditions. The Comelec must ensure that its rules do not become instruments of injustice that disenfranchise willing candidates and, in turn, the electorate," the court said.
With this ruling, the court ordered Comelec to accept Balintay's COC and include his name in the official list of candidates for Zambales governor in the 2025 elections.
