Labo v comelec 1989

• Sole issue of QW being paid out of time. 21 days late. QW was field 7 days after proclamation on
20jan1988. Deadline is 30han
• Defense
o Filed ahead of time before proc and fee offered but this was rejected because comelec
said it was a pre-proclamation controversy
o Comelec declared it a QW late
• P: filing fees mandatory on Res. No. 1450 of the respondent COMELEC, promulgated on January
12, 1988, and February 26, 1980, respectively.
o PR: not yet in effect because res no 1996 only took effect on 3march1988 when it was
published