In the Philippines, election cases before the Commission on Elections (COMELEC) require a majority vote to reach a decision. This case clarifies what happens when the COMELEC en banc, the commission’s full body, cannot reach a majority decision on a motion for reconsideration. The Supreme Court ruled that if the COMELEC en banc fails to reach a majority vote after a rehearing on a case originally filed with the commission, the case is dismissed. This outcome underscores the importance of securing a clear majority within the COMELEC to overturn decisions made by its divisions and affects candidates involved in election disputes.

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The case of Legaspi v. COMELEC (G.R. No. 216572) arose from the 2013 mayoral election in Norzagaray, Bulacan. Feliciano Legaspi, a candidate for mayor, filed a disqualification case against Alfredo Germar, who won the election, and Rogelio P. Santos, Jr., a winning councilor, alleging rampant vote buying. After the COMELEC First Division initially disqualified Germar and Santos, the COMELEC en banc, on motion for reconsideration, could not reach a majority decision on the matter, even after a rehearing. This deadlock led to the dismissal of Legaspi’s petition, prompting him to elevate the matter to the Supreme Court.

At the heart of this case is Section 7 of Article IX-A of the Constitution, which mandates that each constitutional commission, including the COMELEC, must decide cases by a “majority vote of all its [m]embers.” Complementing this is Section 6, Rule 18 of the COMELEC Rules of Procedure, which outlines the course of action when the commission is equally divided or unable to secure the necessary majority. The rule stipulates a rehearing, and if a decision remains elusive, the action is dismissed if originally commenced in the COMELEC. The Supreme Court was asked to clarify the interpretation and application of these provisions, particularly in the context of a motion for reconsideration before the COMELEC en banc.

The Supreme Court, in its decision, emphasized the distinction between cases originally commenced in the COMELEC and those that are appealed to it. The Court affirmed that a disqualification case, such as the one filed by Legaspi, is an action “originally commenced in the commission,” even if it reaches the en banc only through a motion for reconsideration. This interpretation contrasts with cases where the COMELEC exercises appellate jurisdiction, in which the judgment or order appealed from stands affirmed if the en banc fails to reach a majority decision.

The petitioner argued that the failure of the COMELEC en banc to reach a majority vote should only result in the denial of the motion for reconsideration and the affirmance of the division’s decision. However, the Supreme Court rejected this argument, explaining that the COMELEC acts on election cases under a “single and integrated process.” In this view, the motion for reconsideration is not an appeal but a continuation of the existing process, and the case maintains its original nature as one filed before the commission.

In arriving at its conclusion, the Supreme Court referenced its earlier decision in Mendoza v. COMELEC, which similarly involved an election protest. In Mendoza, the Court held that when the COMELEC en banc fails to reach a majority decision on a motion for reconsideration in an original election case, the protest itself is dismissed. Building on this precedent, the Supreme Court in Legaspi underscored that the COMELEC en banc’s inability to muster the required majority leads to the dismissal of the action, regardless of the ruling of the division.

Justice Velasco, in his dissenting opinion, raised concerns about this interpretation of Section 6, Rule 18 of the COMELEC Rules of Procedure. He argued that the failure of the COMELEC en banc to reach a majority vote should only lead to the dismissal of the “proceeding” (i.e., the motion for reconsideration), not the “action” (i.e., the election case itself). However, the majority of the Court disagreed, emphasizing that the terms “action” and “proceeding” should be understood within the context of the COMELEC Rules as a whole. According to the Supreme Court, the dissenting interpretation would effectively allow a minority to overturn a division decision, undermining the adjudicatory powers of the COMELEC divisions.

Moreover, the Supreme Court also addressed the argument that the COMELEC en banc’s interpretation of Section 6, Rule 18 could lead to absurd results. The Court disagreed, stating that there is no “absurdity” in the fact that the decision of a division in an election case ceases to be a COMELEC decision as a consequence of the failure of the COMELEC en banc to reach a majority vote on reconsideration. The decision is a natural and logical consequence of the Constitution, as well as its application.

Ultimately, the Supreme Court dismissed Legaspi’s petition, finding no grave abuse of discretion on the part of the COMELEC en banc. The Court held that the dismissal of the electoral aspect of Legaspi’s disqualification case was in accordance with the provisions of the COMELEC Rules of Procedure and consistent with established jurisprudence on the matter. For candidates and parties involved in election disputes, this ruling reinforces the importance of securing a clear majority within the COMELEC to overturn decisions made by its divisions. The ruling clarifies that a divided commission can result in the dismissal of an original action, regardless of its merits.

FAQs

What was the key issue in this case?	The key issue was whether the COMELEC en banc correctly dismissed a disqualification case when it failed to reach a majority decision after a rehearing.
What did the Supreme Court rule?	The Supreme Court ruled that the COMELEC en banc acted correctly in dismissing the case because it was an action originally commenced in the COMELEC and the commission could not reach a majority decision.
What happens if the COMELEC en banc is divided?	If the COMELEC en banc is equally divided or unable to reach a majority, the case is reheard. If no decision is reached after the rehearing, the action is dismissed if originally commenced in the COMELEC.
What is the significance of Mendoza v. COMELEC?	Mendoza v. COMELEC established the principle that the COMELEC must reach a majority decision on cases brought before it. It also clarified that the failure to muster the required majority vote leads to the dismissal of the original case.
What does “originally commenced in the commission” mean?	“Originally commenced in the commission” refers to cases initially filed with the COMELEC, either in division or en banc, as opposed to cases that are appealed to it from lower tribunals.
What was Justice Velasco’s dissenting opinion?	Justice Velasco argued that the failure to reach a majority vote should only result in the dismissal of the motion for reconsideration, not the entire case. He believed the division’s ruling should stand when there is no majority decision from the en banc.
Why did the Supreme Court disagree with the dissenting opinion?	The Supreme Court disagreed because the COMELEC acts on election cases under a single process. It also stated that the dissenting interpretation undermined the adjudicatory powers of the COMELEC divisions.
What is the practical implication of this ruling?	The practical implication is that parties in election disputes must secure a clear majority within the COMELEC to overturn decisions made by its divisions, as a divided commission can lead to dismissal.

This case serves as a reminder of the crucial role of majority decision-making in election disputes before the COMELEC. The Supreme Court’s affirmation of the COMELEC en banc’s dismissal underscores the importance of building consensus and securing a clear majority to achieve a desired outcome in election-related cases. This decision emphasizes that the COMELEC’s inability to reach a decision leads to the dismissal of an action originally filed with the commission, solidifying the existing ruling.

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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: Legaspi v. COMELEC, G.R. No. 216572, September 01, 2015