In Diangka vs. COMELEC, the Supreme Court affirmed the Commission on Elections’ (COMELEC) decision to disqualify a mayoral candidate due to acts of terrorism committed by her husband. This case underscores that a candidate can be held accountable for actions that create an environment of fear and disrupt the electoral process, even if those actions are carried out by close relatives. This ruling emphasizes the importance of ensuring fair and peaceful elections, free from intimidation, and highlights the COMELEC’s authority to disqualify candidates who benefit from such unlawful acts.

Beyond the Ballot: Can a Candidate Be Disqualified for a Spouse’s Actions?

The heart of the matter in Diangka vs. COMELEC revolves around whether a candidate can be disqualified from running for office based on the actions of their spouse, specifically when those actions constitute acts of terrorism aimed at enhancing the candidate’s chances of winning. Maimona Diangka, a candidate for Mayor of Ganassi, Lanao del Sur, faced disqualification proceedings after her rival, Ali Balindong, alleged that she and her husband, the incumbent mayor, engaged in acts of terrorism to gain an unfair advantage in the elections. The COMELEC found Diangka liable and disqualified her, a decision she challenged before the Supreme Court.

At the core of the legal framework is Section 68 of the Omnibus Election Code, which specifies the grounds for disqualification of a candidate. Crucially, this section includes the commission of “acts of terrorism to enhance his candidacy.” The question then becomes: can acts of terrorism committed by someone else, particularly a spouse, be attributed to the candidate? The Supreme Court had to delve into the specifics of the case to determine the extent of Diangka’s involvement, whether direct or indirect, in the alleged acts of terrorism. The Court had to reconcile the principle of individual culpability with the reality of political dynamics, especially in local settings where family ties often play a significant role.

The COMELEC presented two key incidents of alleged terrorism. The first involved compelling watchers of rival candidates to leave a precinct, allowing ballots to be filled out in Diangka’s favor. The second involved a disruption at the Ganassi Central Elementary School, where the incumbent mayor and armed men allegedly created commotion and intimidated voters. Diangka countered by claiming that she was not directly involved in these acts and that holding her responsible based on her husband’s actions violated the principle of res inter alios acta, which states that one person is not bound by the acts of another. The Supreme Court, however, found that the evidence suggested Diangka’s direct or indirect involvement.

Regarding the first incident, the COMELEC found that Diangka was present in the ambulance used to transport election paraphernalia, and that this ambulance deviated from its route to allow the intimidation of rival watchers. The Court highlighted Diangka’s presence and her control over the ambulance’s driver, drawing the conclusion that she was an active participant, or at least acquiescent, in the acts of intimidation. Importantly, the Court emphasized the significance of her presence in the ambulance. Consider this statement from the ruling:

Respondent’s admission that she was a passenger in the ambulance vehicle on election day already speaks volumes. More so, when respondent admitted that the driver, at her request, dropped her off at her house. Hence, respondent was not a mere passenger of the ambulance but one who controls its driver.

This underscored her ability to influence the situation and her knowledge of the intended disruption. The Court effectively pierced the veil of res inter alios acta by pointing to Diangka’s active role. Turning to the second incident, the Court acknowledged that Diangka was not physically present when her husband allegedly disrupted the voting process at the Ganassi Central Elementary School. However, the Court reasoned that her husband’s actions were clearly intended to benefit her candidacy, and that she could not credibly claim ignorance of his intentions, especially given the political context. As the Court stated:

The incumbent mayor could not have done it just for the heck of it. Rather, it is clear that said terrorist acts were done to favor not just any of the candidates but were calculated to ensure the victory in the polls of a specific candidate, his wife.

The Court gave weight to the fact that Diangka was essentially running as a proxy for her husband, who was term-limited. The Court found a “common purpose and community of interest” between the husband and wife. The Court also rebuffed Diangka’s claim that she was denied due process. It noted that she was given the opportunity to present her case and evidence, both in her initial answer and in her subsequent motion for reconsideration. The COMELEC’s decision to rely on affidavits and other documentary evidence, without conducting clarificatory questioning or cross-examination, was deemed permissible under the summary nature of disqualification proceedings.

Moreover, the Court emphasized that technical rules of evidence are relaxed in administrative proceedings. As the Supreme Court affirmed the COMELEC’s decision, it reinforced the principle that actions intended to create an atmosphere of fear and undermine the integrity of the electoral process cannot be tolerated, even if carried out through intermediaries. The ruling serves as a stern warning against using violence or intimidation to gain political advantage and reaffirms the COMELEC’s power to ensure fair and honest elections. This also reaffirms that in election cases, the COMELEC is given wide latitude in ascertaining the facts.

FAQs

What was the key issue in this case?	The key issue was whether a candidate could be disqualified for acts of terrorism committed by her spouse to enhance her candidacy, even if she claimed no direct involvement.
What is Section 68 of the Omnibus Election Code?	Section 68 lists the grounds for disqualification of a candidate, including committing acts of terrorism to enhance their candidacy. This provision was central to the COMELEC’s decision to disqualify Diangka.
What does res inter alios acta mean?	Res inter alios acta is a legal principle stating that a person’s rights cannot be prejudiced by the actions of another. Diangka argued this principle applied to her, but the Court disagreed.
How did the COMELEC prove Diangka’s involvement?	The COMELEC pointed to Diangka’s presence in the ambulance used to intimidate rival watchers, and her control over the driver, as evidence of her direct or indirect participation.
Did the Supreme Court find that Diangka was denied due process?	No, the Supreme Court found that Diangka was given sufficient opportunity to present her case and evidence, both initially and in her motion for reconsideration.
Why did the COMELEC rely on affidavits instead of live testimony?	Disqualification proceedings are considered summary in nature, allowing the COMELEC to rely on affidavits and documentary evidence without necessarily conducting live testimony or cross-examination.
What was the significance of Diangka’s husband being term-limited?	The fact that Diangka’s husband was term-limited suggested that she was running as a proxy for him, and that his actions were intended to benefit her candidacy.
What is the main takeaway from this case?	The main takeaway is that candidates can be held accountable for actions that create an environment of fear and disrupt the electoral process, even if those actions are carried out by close relatives.

In conclusion, Diangka vs. COMELEC serves as a reminder that the pursuit of political power must be conducted within the bounds of the law and with respect for the democratic process. Acts of violence, intimidation, and terrorism have no place in elections, and those who engage in such behavior, directly or indirectly, will be held accountable.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: MAIMONA H. N. M. S. DIANGKA v. COMMISSION ON ELECTIONS and ATTY. ALI M. BALINDONG, G.R. No. 139545, January 28, 2000