RULING

 The Court ruled in the affirmative. Section 13 of RA No. 7166 sets the
Ejercito vs. COMELEC current allowable limit on expenses of candidates and political parties for
G.R. NO. 212398 | Campaign election campaign.
 Moreover, RA 7166 does not repeal Sections 100, 101, and 103 of the
DOCTRINE/LESSON OF THE CASE Omnibus Election Code (OEC) as these provisions were merely amended
● insofar as the allowable amount is concerned.
 In tracing the legislative history of Sections 100, 101, and 103 of the OEC,
FACTS
it can be said, therefore, that the intent of our lawmakers has been
 3 days prior to the May 2013 National and Local Elections, a petition for
disqualification was filed by San Luis before the Office of the COMELEC consistent through the years: to regulate not just the election expenses of
Clerk in Manila against Ejercito, who was a fellow gubernatorial the candidate but also of his or her contributor/supporter/donor as well as
candidate and, at the time, the incumbent Governor of the Province of by including in the aggregate limit of the former’s election expenses those
Laguna. incurred by the latter.
 The petition argued among others, that a candidate for the position of  The phrase “those incurred or caused to be incurred by the candidate” is
Provincial Governor of Laguna is only authorized to incur an election sufficiently adequate to cover those expenses which are contributed or
expense amounting to P4,576,566
donated in the candidate’s behalf.
 Ejercito, in total disregard and in violation of the provision of law,
exceeded his expenditures in relation to his campaign for the 2013 election  By virtue of the legal requirement that a contribution or donation should
 For television campaign commercials alone, Ejercito already spent the bear the written conformity of the candidate, a contributor/supporter/donor
sum of P23,730,784 based on the party’s official monitoring certainly qualifies as “any person by such candidate or treasurer.” There
 Even assuming that Ejercito was given 30% discount as prescribed under should be no distinction in the application of a law where none is
the Fair Election Act, he still exceeded in the total allowable expenditures indicated.
for which he paid the sum of P16,611,549
 Ejercito claims that the advertising contracts between ABS-CBN
Corporation and Scenema Concept International, Inc. were executed by an
identified supporter without his knowledge and consent as, in fact, his
signature thereon was obviously forged.
 Even assuming that such contract benefited him, he alleges that he should
not be penalized for the conduct of third parties who acted on their own
without his consent.
 He also argued, among others, that the legislature imposes no legal
limitation on campaign donations.
 He vigorously asserts that COMELEC Resolution No. 9476 distinguishes
between “contribution” and “expenditure” and makes no proscription on
the medium or amount of contribution made by third parties in favor of the
candidates, while the limit set by law, as appearing in COMELEC
Resolution No. 9615, applies only to election expenditures of candidates.

ISSUES
 Whether or not contributions of supporters are included in the aggregate
limit of candidate’s election expenses? - YES