Sinaca vs.

COMELEC
G.R. No. 135691 (1999)
Ponente: Davide
FACTS:
LAKAS-NUCD-UMPD had 2 opposing factions judging the May 11, 1998 elections -- the
Barbers wing, which nominated Grachil G. Canoy and was headed by Robert Barbers, and the
Matugas wing, which nominated Teodoro F. Sinaca, Jr. and was headed by Francisco Matugas.
Miguel Mula, a candidate for vice-mayor belonging to the Barbers wing filed a petition for
disqualification against Teodoro, a mayoral candidate in Malimono, Surigao del Norte, which
COMELEC granted. Consequently, Teodoro filed a motion for reconsideration. The same date
that Teodoro filed a motion for reconsideration, Sinaca Sinaca, an independent candidate,
withdrew his certificate of candidacy, became a member of LAKAS, and ran as the substitute
mayoral candidate under the Matugas wing. As such, he filed another certificate of candidacy,
now as mayoral candidate under LAKAS.
On May 11, 1998, Mula filed another petition for disqualification against Sinaca, contending that
his nomination as a substitute candidate is illegal because prior to being a substitute candidate,
he was not part of any party; his nomination bears only the approval of Provincial Chair Matugas,
without consultation with the other party membes; and substitution takes place only when the
disqualification of a party results to losing representation, but in this case, LAKAS still had
Canoy as the party's candidate.
On May 28, 1998, COMELEC dismissed Mula's petition and upheld Sinaca's candidacy
because Matugas was allowed to nominate Sinaca as substitute candidate, and that the petition
was rendered moot and academic because Sinaca was already declared winner of the election,
and has already taken his oath of office. Eventually, Mula filed a motion for reconsideration. On
October 6, 1998, COMELEC en ban issued a resolution disqualifying Sinaca solely on the basis
of being an independent candidate prior to his nomination as a substitute candidate. Section 77
of the Omnibus Election Code provides that in the event that an official candidate dies,
withdraws or is disqualified on the last day of the filing of certificates of candidacy, only a person
belonging to the same party may replace the candidate.
ISSUE: W/N COMELEC was correct in disqualifying Sinaca
HELD:
NO. Matugas had authority to nominate a candidate without Barbers' concurrence because he
was designated as LAKAS HQ's Deputy Secretary General and National Secretariat Executive
Director. Sinaca was also rightfully a member of LAKAS. The Supreme Court said that "a
political party has the right to identify the people who constitute the association and to select a
standard bearer who best represents the party's ideologies and preference. Political parties are
generally free to conduct their internal affairs free from judicial supervision; this common-law
principle of judicial restraint, uprooted in the constitutionally protected right of free association,
serves the public interest by allowing political processes to operate without undue interference.
Thus, the rule is that the determination of disputes as to party nominations rests with the
party, in the absence of statutes giving the court's jurisdiction."