The Supreme Court held that when a candidate is disqualified by final judgment before an election, votes cast in their favor are considered stray and should not be counted. This ruling underscores the importance of adhering to electoral laws, as a pre-election disqualification renders a candidacy legally non-existent, preventing the disqualified individual from assuming office even if they receive the majority of votes. This ensures that only eligible candidates, as determined by final judgment before election day, can hold public office.

When Does a Disqualification Ruling Truly Disqualify? Examining Cayat v. COMELEC

In Cayat v. COMELEC, the central issue revolved around the enforceability of a disqualification ruling against Rev. Fr. Nardo B. Cayat, a candidate for mayor of Buguias, Benguet. Cayat’s certificate of candidacy was canceled due to a prior conviction for a crime involving moral turpitude. The critical question was whether this disqualification became final before the election date, and if so, what the consequences would be for the votes cast in his favor.

The case hinged on the timeline of events following the Commission on Elections (COMELEC) First Division’s resolution to cancel Cayat’s certificate of candidacy. Cayat argued that he was not properly notified of the promulgation of the resolution and that his subsequent motion for reconsideration was valid. However, the Supreme Court found that Cayat failed to pay the required filing fee for his motion, rendering it pro forma and ineffective. Consequently, the COMELEC’s initial disqualification order became final and executory before the election day.

A significant aspect of the Court’s analysis focused on the applicability of Section 6 of Republic Act No. 6646, The Electoral Reforms Law of 1987, which distinguishes between disqualifications finalized before and after an election. The Court emphasized that because Cayat’s disqualification was finalized 23 days before the election, the votes cast for him were considered stray. This is based on the mandatory provision that “any candidate who has been declared by final judgment to be disqualified shall not be voted for, and the votes cast for him shall not be counted.”

The Court distinguished this case from previous rulings, such as Labo, Jr. v. COMELEC, where the disqualification became final only after the election. In Labo, the doctrine on the rejection of the second placer was applied because the judgment declaring the candidate’s disqualification had not become final before the elections. In contrast, the Cayat case fell squarely under the first scenario outlined in Section 6 of the Electoral Reforms Law, where a candidate is disqualified by final judgment before the election, rendering any votes cast for them invalid.

Furthermore, the Court addressed concerns about disenfranchisement, clarifying that the 8,164 voters who cast their votes for Cayat were, in effect, voting for a non-candidate. This highlights a crucial distinction: a candidate disqualified by final judgment before an election cannot be voted for, and any votes cast for them are considered stray and “shall not be counted.” This legal position underscores the importance of timely and effective enforcement of disqualification orders.

The practical implication of this decision is significant for Philippine electoral law. It reinforces the principle that final judgments regarding a candidate’s eligibility must be respected and enforced before an election takes place. The COMELEC’s actions and the judiciary’s affirmation seek to prevent confusion and potential litigation arising from candidates whose disqualifications have been determined before the electoral process. The decision ultimately protects the integrity of the electoral process, ensuring that only legally qualified individuals hold public office.

FAQs

What was the key issue in this case?	The key issue was whether the votes cast for a candidate disqualified before election day should be counted. The Supreme Court ruled that these votes are considered stray and should not be counted.
When did Cayat’s disqualification become final?	Cayat’s disqualification became final on April 17, 2004, 23 days before the May 10, 2004 elections. This was due to his failure to pay the filing fee for his motion for reconsideration.
What is the effect of a pre-election disqualification?	A pre-election disqualification renders the candidacy legally non-existent. Any votes cast for the disqualified candidate are considered stray and will not be counted.
What is Section 6 of R.A. 6646?	Section 6 of R.A. 6646, The Electoral Reforms Law of 1987, states that a candidate disqualified by final judgment shall not be voted for, and the votes cast for him shall not be counted. It distinguishes between disqualifications before and after the election.
How did this case differ from Labo, Jr. v. COMELEC?	Unlike Labo, Jr. v. COMELEC, where the disqualification became final after the election, Cayat’s disqualification was finalized before the election. This distinction led to different outcomes based on Section 6 of R.A. 6646.
What happens to the votes cast for a disqualified candidate?	The votes cast for a candidate disqualified by final judgment before an election are considered stray and shall not be counted. This is because the law mandates that the disqualified candidate cannot be voted for.
Was there disenfranchisement of voters in this case?	The Court clarified that there was no disenfranchisement because the voters were deemed to have voted for a non-candidate. The law treats such votes as stray, reflecting a choice to vote for someone ineligible.
What was the basis for proclaiming Thomas R. Palileng, Sr. as mayor?	Thomas R. Palileng, Sr. was proclaimed mayor because Cayat’s disqualification became final before the election. Since Cayat was deemed a non-candidate, Palileng was the sole eligible candidate, making his proclamation proper.

The Supreme Court’s decision in Cayat v. COMELEC serves as a reminder of the importance of adhering to legal processes and timelines in election law. Enforcing disqualification orders before elections is crucial for preserving the integrity of the democratic process.

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: Cayat v. COMELEC, G.R. No. 163776 & 165736, April 24, 2007