JUANITO C. PILAR, petitioner,
vs.
COMMISSION ON ELECTIONS, respondent.
vs.
COMMISSION ON ELECTIONS, respondent.
G.R. No. 115245 July 11, 1995
Facts:
On March 22, 1992, petitioner Juanito C. Pilar filed his certificate of candidacy for the position of member of the Sangguniang Panlalawigan of the Province of Isabela. Three days after, the petitioner withdrew his certificate of candidacy.
In M.R. Nos. 93-2654 and 94-0065 dated November 3, 1993 and February 13, 1994 respectively, the COMELEC imposed upon petitioner the fine of Ten Thousand Pesos for failure to file his statement of contributions and expenditures.
Petitioner argues that he cannot be held liable for failure to file a statement of contributions and expenditures because he was a "non-candidate," having withdrawn his certificates of candidacy three days after its filing. Petitioner speculates that "it is . . . clear from the law that candidate must have entered the political contest, and should have either won or lost".
Facts:
On March 22, 1992, petitioner Juanito C. Pilar filed his certificate of candidacy for the position of member of the Sangguniang Panlalawigan of the Province of Isabela. Three days after, the petitioner withdrew his certificate of candidacy.
In M.R. Nos. 93-2654 and 94-0065 dated November 3, 1993 and February 13, 1994 respectively, the COMELEC imposed upon petitioner the fine of Ten Thousand Pesos for failure to file his statement of contributions and expenditures.
Petitioner argues that he cannot be held liable for failure to file a statement of contributions and expenditures because he was a "non-candidate," having withdrawn his certificates of candidacy three days after its filing. Petitioner speculates that "it is . . . clear from the law that candidate must have entered the political contest, and should have either won or lost".
Issue:
Whether or not a candidate is excused in filing his statement of contributions and expenditures after he has withdrawn his certificate of candidacy.
Held:
The petition is dismissed. The court ruled that the filing or withdrawal of certificate of candidacy shall not affect whatever civil, criminal or administrative liabilities which a candidate may have incurred. Petitioner’s withdrawal of his candidacy did not extinguish his liability for the administrative fine. It is not improbable that a candidate who withdrew his candidacy has accepted contributions and incurred expenditures, even in the short span of his campaign. The evil sought to be prevented by the law is not all too remote. Courts have also ruled that such provisions are mandatory as to the requirement of filing.