GR No. 225152

GR No.
225152, October 05, 2021
PARTIDO DEMOKRATIKO PILIPINO-LAKAS NG BAYAN HEREIN v. COMELEC EN BANC
LOPEZ, M., J.:
DOCTRINE:
Notably, the provisions "within thirty (30) days after the day of the election" is preceded by
the phrase "Every candidate and treasurer of the political party shall" and followed by the phrase
"file in duplicate with the offices of the Commission the full, true and itemized statement of all
contributions and expenditures in connection with the election."
FACTS
The COMELEC issued Resolution No. 9991, prescribing the guidelines for the submission of
the SOCEs for the May 9, 2016 national and local elections. The COMELEC reminded the candidates
and the political parties to submit their SOCEs not later than June 8, 2016. The deadline is "final and
non-extendible" and any submission filed beyond such date will not be accepted. This is pursuant to
Section 14 of Republic Act (RA) No. 7166 which provides that the SOCEs must be filed within 30 days
after the day of the elections. the COMELEC En Banc, through Resolution No. 10147, extended the
filing of SOCEs until June 30, 2016. The candidates and political parties who will submit their SOCEs
on or before the new deadline will not incur any administrative liability. The majority of the
commissioners explained that the law in providing that "[n]o person elected to any public office shall
enter upon the duties of his office until he has filed the statement of contributions and expenditures
herein required" implies that the SOCEs may be submitted beyond the 30-day period. Moreover, the
COMELEC previously allowed extension of time in filing the SOCEs due to legal necessity and to
prevent vacuum in the public service. Partido Demokratiko Pilipino-Lakas ng Bayan (PDP-Laban) filed
a Petition for Certiorari questioning COMELEC En Banc Resolution No. 10147. The PDP-Laban argues
that the COMELEC exceeded the limits of its delegated rule-making authority and violated Section 14
of RA No. 7166 that the SOCEs must be filed within 30 days after the elections. Meantime, Leon
Estrella Peralta, Melchor Gruela Magdamo, and Othello Estropigan Dalanon (Peralta, et al.), in their
capacities as taxpayers, moved to intervene in the proceedings. Peralta, et al. reiterate the
mandatory nature of the 30-day period and maintain that any delay will give the candidates and the
political parties the opportunity to fabricate their SOCEs. Also, Peralta, et al. ask that the winning
candidates who did not submit their SOCEs within the required period must be prohibited from
entering their public duties, thus, allowing the rule on succession to operate. Lastly, Peralta, et al.,
insinuate that the commissioners who voted to extend the deadline should be held guilty of betrayal
of public trust.
ISSUE:
Whether or not COMELEC committed grave abuse of discretion when it extended the
deadline for filing of the SOCEs and exempted candidates and political parties from administrative
liabilities in violation of the clear language of the law and legislative intent.
RULING:
Yes. the Court rules that the COMELEC cannot validly extend the deadline for submission of
the SOCEs and exempt the candidates and political parties from administrative liabilities. The Court
agrees with the PDP-Laban and Peralta, et al. that the language of Section 14 of RA No. 7166 is
unambiguous and that the required SOCEs must be filed within 30 days after the elections.
Foremost, verba legis non est recedendum is a basic rule in statutory construction. The maxim
translates "from the words of a statute there should be no departure." Differently stated, a statute
that is clear is not susceptible to interpretation and should be applied regardless of who may be
affected, even if the law is harsh and onerous. The remedy is with Congress to modify or even
abandon the law. Contrary to the COMELEC'S interpretation, the commas separating the phrase
"within thirty (30) days after the day of the election" from the rest of the first sentence of Section 14
of RA No. 7166 do not make the period to file SOCEs extendible. A comma is a punctuation mark
used to divide a sentence, but it does not introduce a new idea. As such, the separated phrase must
relate to the same subject matter which precedes it.

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GR No.

225152, October 05, 2021

PARTIDO DEMOKRATIKO PILIPINO-LAKAS NG BAYAN HEREIN v. COMELEC EN BANC

LOPEZ, M., J.:

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