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JOEL T. MATURAN v. COMELEC

FACTS:

The petitioner filed his certificate of candidacy for the position of Provincial Governor of Basilan in the 2016 National and Local Elections. Allan Patino filed a petition for the petitioner's disqualification, alleging that he failed to file his Statement of Contributions and Expenditures (SOCE) for the 2010 and 2013 elections. The petitioner argued that the petition was moot since he had withdrawn from the mayoralty race during the 2013 elections. The COMELEC First Division issued a resolution finding merit in the petition and declaring the petitioner disqualified from holding public office. The petitioner appealed to the COMELEC En Banc, which denied his appeal. Aggrieved, the petitioner filed a petition for certiorari before the Supreme Court, raising several issues.

ISSUES:

  1. Whether or not the Commission on Elections (COMELEC) committed grave abuse of discretion in declaring the petitioner perpetually disqualified to hold public office.

  2. Whether or not the COMELEC committed grave abuse of discretion in failing to dismiss the petition for disqualification for being moot and academic.

  3. Whether or not the imposition of perpetual disqualification for failure to file the Statement of Contributions and Expenditures (SOCE) more than once is excessively and disproportionately harsh.

RULING:

  1. The petition is dismissed for lack of merit.

PRINCIPLES:

  • The Court will only step in when there is a showing that the COMELEC committed grave abuse of discretion amounting to lack or excess of jurisdiction.

  • The Court will determine if the exercise of power by the COMELEC was capricious, arbitrary, whimsical, or without basis under the law.

  • The penalty of perpetual disqualification to hold public office may be properly imposed on a candidate who repeatedly fails to submit his SOCE in accordance with Section 14 of R.A. No. 7166.

  • The penalty does not amount to cruel, degrading, and inhuman punishment prohibited by the Bill of Rights.

  • The duty to file the SOCE is mandatory for every candidate, even if they withdraw their candidacy.

  • The use of the word "shall" in a statute implies that it is mandatory and imposes a duty that may be enforced.