In Revilla v. COMELEC, the Supreme Court ruled that motions for reconsideration of decisions made by a COMELEC Division must be decided by the COMELEC en banc, not just a division. This ensures that all members of the Commission have the opportunity to review and decide on critical election-related issues, reinforcing the integrity and fairness of the electoral process. The decision emphasizes the constitutional mandate for the COMELEC to act as a whole when reconsidering its divisions’ rulings, thereby safeguarding the rights of candidates and the electorate by preventing potentially biased or incomplete reviews.

Clash in Cabligan: Was Revilla’s Appeal Undermined by COMELEC’s Division?

The dispute arose from the 2007 barangay elections in Cabligan, Matanao, Davao del Sur, where Eugenio T. Revilla, Sr. and Gerardo L. Lanoy vied for the position of Punong Barangay. Initial counts favored Revilla, but Lanoy filed an election protest, leading to a recount that declared Lanoy the winner. Revilla appealed to the COMELEC, but his appeal was initially dismissed by the Second Division for failing to pay the full appeal fee promptly. This dismissal sparked a series of motions for reconsideration and procedural challenges, ultimately bringing the case before the Supreme Court.

At the heart of the matter was whether the COMELEC Second Division acted correctly in denying Revilla’s motions for reconsideration. The critical point of contention was the constitutional requirement that motions for reconsideration be resolved by the COMELEC en banc. Article IX-C, Section 3 of the 1987 Constitution stipulates that while the COMELEC may operate in divisions, motions for reconsideration must be decided by the full Commission. The court emphasized that this requirement is not merely procedural but constitutional, designed to ensure that decisions with significant impact receive comprehensive review.

“Sec. 3. The Commission on Elections may sit en banc or in two divisions, and shall promulgate its rules of procedure in order to expedite disposition of election cases, including pre-proclamation controversies. All such election cases shall be heard and decided in division, provided that motions for reconsideration of decisions shall be decided by the Commission en banc.“

The Supreme Court noted that the COMELEC Rules of Procedure further reinforce this constitutional mandate. Specifically, Rule 19, Sections 5 and 6, outline the process by which motions for reconsideration must be certified to the COMELEC en banc for resolution. These rules ensure that no single division can unilaterally alter or uphold decisions without the full commission’s consideration.

“Sec. 5. How Motion for Reconsideration Disposed Of. -Upon the filing of a motion to reconsider a decision, resolution, order or ruling of a Division, the Clerk of Court concerned shall, within twenty-four (24) hours from the filing thereof, notify the Presiding Commissioner. The latter shall within two (2) days thereafter certify the case to the Commission en banc.”

“Sec. 6. Duty of Clerk of Court of Commission to Calendar Motion for Reconsideration.—The Clerk of Court concerned shall calendar the motion for reconsideration for the resolution of the Commission en banc within ten (10) days from the certification thereof.“

Building on this principle, the Supreme Court cited a similar case, Aguilar v. COMELEC, where it had previously ruled that a COMELEC division’s denial of a motion for reconsideration was a grave abuse of discretion. The Court clarified that this rule applies irrespective of whether the motion fee has been fully paid. The decision to either refuse action until the fee is paid or dismiss the action lies with the COMELEC en banc, not a division. Here it is important to recognize the meaning of grave abuse of discretion: a decision so outrageously wrong it exceeds the bounds of reason.

In addition to the procedural misstep, the Court also addressed the issue of the appeal fee. Revilla had initially paid P1,000.00 as an appeal fee before the MCTC, which the Court deemed sufficient to perfect his appeal under A.M. No. 07-4-15-SC. The subsequent requirement to pay an additional P3,200.00 to the COMELEC Cash Division did not retroactively invalidate the perfected appeal. While Rule 22, Section 9(a) and Rule 40, Section 18 of the COMELEC Rules allow for dismissal due to non-payment of fees, the Court held that dismissing Revilla’s appeal under these circumstances was a grave abuse of discretion, given that the initial payment was made before COMELEC Resolution No. 8486 clarified the additional fee requirement. By ordering the case to be remanded to the COMELEC Second Division, the Court provided an avenue for fair disposition.

FAQs

What was the key issue in this case?	The central issue was whether the COMELEC Second Division erred in denying Revilla’s motions for reconsideration, which constitutionally must be decided by the COMELEC en banc. This ruling emphasizes the importance of the full Commission’s review in significant election disputes.
Why is it important for the COMELEC en banc to decide motions for reconsideration?	Requiring the COMELEC en banc to decide motions for reconsideration ensures a comprehensive review by all members, which guards against biased or incomplete assessments. This is vital for maintaining the integrity and fairness of the electoral process.
What does the Constitution say about the COMELEC’s structure?	Article IX-C, Section 3 of the 1987 Constitution allows the COMELEC to operate in divisions but mandates that motions for reconsideration be decided by the full Commission en banc. This framework ensures broad oversight in critical decisions.
What happened with the appeal fee in this case?	Revilla initially paid an appeal fee of P1,000.00 to the MCTC, which the Court found sufficient to perfect his appeal. The later requirement for an additional fee did not invalidate his perfected appeal.
What is the significance of COMELEC Resolution No. 8486 in this case?	COMELEC Resolution No. 8486 clarified the appeal fee requirement, but it was issued after Revilla had already perfected his appeal with the initial payment. The Court considered this timing in determining that the dismissal of his appeal was an abuse of discretion.
What was the outcome of the Supreme Court’s decision?	The Supreme Court granted the petition for certiorari, annulling the COMELEC Second Division’s orders and remanding the case for proper disposition. This means the case was sent back to the COMELEC for reconsideration by the full Commission.
What does “grave abuse of discretion” mean in this context?	Grave abuse of discretion refers to a decision that is so patently and grossly wrong it exceeds the bounds of reason or legal authority. The Court found that the COMELEC Division’s actions met this threshold.
What is the practical implication of this ruling for future election cases?	This ruling reinforces the constitutional requirement for COMELEC en banc decisions on motions for reconsideration, ensuring a higher standard of review. It safeguards against procedural shortcuts that could undermine the fairness of election outcomes.

This case serves as a reminder of the importance of adhering to constitutional and procedural rules within the election process. By requiring the COMELEC en banc to handle motions for reconsideration, the Supreme Court upholds the principles of fairness, transparency, and thorough review in election disputes.

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: Eugenio T. Revilla, Sr. v. COMELEC and Gerardo L. Lanoy, G.R. No. 187428, October 16, 2009