In Maruhom v. COMELEC, the Supreme Court affirmed that the Commission on Elections (COMELEC) has the authority to disqualify a candidate who makes false material representations in their Certificate of Candidacy (COC). Specifically, the Court found that Jamela Salic Maruhom falsely claimed to be a registered voter in Marantao, Lanao del Sur, when she had a prior subsisting voter registration in Marawi City. This ruling underscores the importance of truthful declarations by candidates and the COMELEC’s power to ensure the integrity of the electoral process.

Double Registration Dilemma: Can a Candidate Be Disqualified for False Voter Information?

The case arose from the 2007 mayoral election in Marantao, Lanao del Sur, where Jamela Salic Maruhom and Mohammadali “Mericano” A. Abinal were candidates. Abinal filed a petition to disqualify Maruhom, arguing that she was a double registrant and had made false statements in her COC. The core legal question was whether the COMELEC had the jurisdiction to declare Maruhom’s Marantao registration void and disqualify her candidacy based on false material representations. This put into question the very scope of COMELEC’s authority.

The COMELEC’s First Division granted Abinal’s petition, finding that Maruhom’s Marantao registration was void ab initio because she already had a subsisting registration in Marawi City. The COMELEC En Banc affirmed this decision. Maruhom then filed a Petition for Certiorari with the Supreme Court, arguing that the COMELEC lacked jurisdiction to rule on her voter registration and that she was not a double registrant.

The Supreme Court disagreed with Maruhom’s arguments. It emphasized that the issue was not about denying her right to register as a voter, but about her making false material representations in her COC. Under Section 78 of the Omnibus Election Code (OEC), a false representation of material fact in the COC is a ground for denial or cancellation. This material fact includes a candidate’s eligibility or qualification for elective office, such as their status as a registered voter.

The Court cited COMELEC Minute Resolution No. 00-1513, which states that when a voter has multiple registrations, the first registration subsists, and subsequent registrations are void ab initio. Therefore, Maruhom’s Marawi registration was valid, and her Marantao registration was void. By declaring herself a registered voter in Marantao, she made a false material representation in her COC.

The Court also found that Maruhom deliberately concealed her subsisting Marawi registration. Before filing her COC, she had requested the COMELEC to cancel her Marawi registration, but this request was still pending when she filed her COC for Marantao. The Court emphasized that an elective office is a public trust, and candidates should not make false representations. As such, this highlighted an underlying need for transparency in the process.

Moreover, the Court affirmed the COMELEC’s broad powers to enforce election laws and ensure honest, peaceful, and credible elections. Even if the Municipal Trial Court (MTC) has jurisdiction over inclusion and exclusion of voters, the COMELEC’s power to determine the validity of a COC extends to resolving voter registration issues relevant to a candidate’s qualifications.

The Supreme Court emphasized it will not interfere with COMELEC decisions unless there is grave abuse of discretion. In this case, the Court found no such abuse, as the COMELEC’s decision was based on substantial evidence and a correct interpretation of the law.

The significance of this ruling lies in its emphasis on the importance of truthful declarations in COCs and the COMELEC’s authority to enforce these requirements. The case underscores that candidates must be forthright about their qualifications, including voter registration status, to maintain the integrity of the electoral process.

FAQs

What was the key issue in this case?	The key issue was whether the COMELEC had the jurisdiction to disqualify a candidate for making false material representations in their Certificate of Candidacy (COC), specifically regarding their voter registration status.
What is a Certificate of Candidacy (COC)?	A COC is a sworn statement filed by a person seeking an elective public office, declaring their qualifications and eligibility for the position. It contains information such as name, date of birth, residence, and voter registration details.
What is considered a false material representation in a COC?	A false material representation is an untrue statement about a fact that affects a candidate’s eligibility or qualification for office, such as citizenship, residence, or voter registration status.
What is the effect of double registration?	Under COMELEC rules, when a voter has multiple registrations, the first registration is considered valid, and subsequent registrations are void ab initio. This means the later registrations are invalid from the beginning.
What is the COMELEC’s Minute Resolution No. 00-1513?	COMELEC Minute Resolution No. 00-1513 states that when a voter has multiple registrations, the first registration subsists, and any subsequent registrations are void from the start.
Can a candidate request the cancellation of their voter registration?	Yes, a voter can request the cancellation of their registration, but the cancellation is not effective until the COMELEC officially acts upon the request. A pending request does not automatically invalidate the original registration.
What is the role of the MTC (Municipal Trial Court) in voter registration issues?	The MTC has original jurisdiction over cases of inclusion and exclusion of voters in their respective cities or municipalities. This jurisdiction, however, does not limit the COMELEC’s powers concerning COCs.
What is grave abuse of discretion by the COMELEC?	Grave abuse of discretion refers to a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction, or an exercise of power in an arbitrary and despotic manner, such that this implies ignoring due process and fair proceedings.

The Maruhom v. COMELEC case reinforces the need for accuracy and transparency in the electoral process. By upholding the COMELEC’s authority to disqualify candidates who make false statements, the Supreme Court promotes the integrity of elections and ensures that only qualified individuals hold public office.

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: Maruhom v. COMELEC, G.R. No. 179430, July 27, 2009