De Guzman vs Commission on Elections Case Digest

De Guzman vs Commission on Elections

GR 129118 19 July 2000

Facts:

Comelec reassigned petitioners to other stations pursuant to Section 44 of the Voter’s registration act. The
act prohibits election officers from holding office in a particular city or municipality for more than 4 years. Petitioners
claim that the act violated the equal protection clause because not all election officials were covered by the
prohibition.

Petitioners contend that RA 8189 Section 44 is unconstitutional as it violates the equal protection clause
enshrined in the constitution; that it violates constitutional guarantee on security of civil servants; that it undermines
the constitutional independence of comelec and comelec’s constitutional authority; that it contravenes the basic
constitutional precept; that it is void for its failure to be read on 3 separate readings

Issue:

Whether or Not section 44 of RA 8189 is unconstitutional

Ruling:

No, RA 8189 Sec 44 is not unconstitutional. It has not violated the equal protection clause. It is intended to ensure the
impartiality of election officials by preventing them from developing familiarity with the people of their place of
assignment. Large-scale anomalies in the registration of voters cannot be carried out without the complicity of
election officers, who are the highest representatives of Comelec in a city or municipality.

G.R.No. 129118 (July 19, 2000)

FACTS: Section 44 of the Voter’s Registration Act provided that no election officer shall hold office in a
particular municipality or city for more than 4 years. In accordance with it, the Comelec reassigned petitioners, who
were election officers to other stations. Petitioners argued that the provision was not expressed in the title of the law,
which is “An Act Providing for a General Registration of Voters, Adopting a System of Continuing Registration,
Prescribing the Procedures Thereof and Authorizing the Appropriation of Fund Thereof”.
HELD: The contention is untenable. Section 44 is relevant to the subject matter of registration as it seeks to ensure
the integrity of the registration process by providing a guideline for the Comelec to follow in the reassignment of
election officers.
FACTS: Section 44 of the Voter’s Registration Act provided that no election officer shall hold office in a particular
municipality or city for more than 4 years. In accordance with it, the Comelec reassigned petitioners, who were
election officers to other stations. Petitioner argue that the law undermined the constitutional authority of the Comelec
to appoint its own officials.
HELD: The law merely provides the basis for the transfer of an election officers and does not deprive the Comelec of
its power to appoint its officials.