Gatchalian v. COMELEC, G.R. No.

32560, 22 October 1970 General words construed generally Facts: Pursuant to the request of the advertising firms and associations of the Philippines, COMELEC promulgated Resolution No. RR 707 which states that donations of billboards to the Commission by foreigners or companies or corporations owned and controlled partially or wholly by foreigners are not covered by Section 56 of the Revised Election Code. The body also issued Resolution RR-731 which states that the ban in Section 46 of the Revised Election Code, as amended, does not cover campaign funds and other contributions by the Advertising Council of the Philippines and other contributions by the Advertising Council of the Philippines and others similarly situated, during the 120 days immediately preceding a regular or special election. Petitioner, as a candidate in the election for delegates to the Constitutional Convention, filed a complaint with the COMELEC assailing the validity of the both resolutions, alleging that both are violative of Section 56 of the Revised Election Code, as amended, which provides that: No foreigner shall aid any candidate, directly or indirectly, or to take part in or to influence in any manner any elections. The prohibited active intervention of foreigners thereunder may consist of: (1) aiding any candidate, directly or indirectly, in any election; (2) taking part in any election; and (3) influencing in any manner any election. The COMELEC, however, denied the petitioners motion, declaring "that contributi ons by foreigners to the COMELEC Billboards Committee for the purpose of financing costs of COMELEC billboards are not made in aid or support of any particular candidate in a particular district and that the allocation of space for its candidate is allowed by lottery, nor would it in any way influence the result of the election, ... .He then filed an appeal with the Court, contending that said order of the COMELEC is null and void as contrary to law or having been issued in excess of the powers of the Commission on Elections or in grave abuse of its discretion, and praying for a writ of preliminary as well as permanent injunction. No restraining order was issued as COMELEC itself did not implement the said resolution. Issue: Whether or not the term any elections, foreigner, and any candidate; as well as the terms aid, take part, and influence, as contemplated In Section 56 of the Revised Election Code, had other meanings Held: The term any elections definitely comprehends or applies to election of delegates Constitutional Convention. Foreigner, on the other hand, refers to both natural and juridical persons or associations or organized groups, as provided by Section 39 of Article 3 of the Revised Election Code, broadening the application of the term and not limiting the prohibition to natural persons only. Any candidate likewise comprehends some candidates or all candidates. The terms aid, to take part, and influence, were also construed in their general sense- with aid referring to to support, to help, to assist or to strengthen or to act in cooperation with; "to take part" means to participate or to engage in; and "influence" means to use the party's endeavors, though he may not be able to carry his point, or to exert or have an effect on the nature or behaviour of, or affect the action or thought of, or modify; or to sway; to persuade; to affect; to have an effect on the condition or development of; to modify or act upon physically, especially in some gentle, subtle, or gradual way; or to exert or maintain a mental or moral power upon or over; to effect or sway by modifications, feelings or conduct. There is nothing in the Revised Election Code which impliedly or expressly prescribes a different meaning to the aforementioned terms. Hence, they should be understood in their general sense. There was likewise no manifest or expressed intention that the meaning of the words were to be restricted or limited. Where general terms are used, the terms are to be understood in their general meaning, unless it is expressed that they have acquired a special and restricted meaning. Hence, in this case, generalia verba sunt generaliter intelligenda applies. The billboard contributions may not specifically favor a single candidate, but the effect that all candidates benefit from the contribution amounts to an assistance greater than the aid that may be given to one candidate. Allowing such undesirable alien influence will inevitably lead to a circumvention of the laws protecting our national interest. The practice allegedly condoned by the COMELEC in the subject resolutions, therefore, constitute a violation of the Revised Election Code. The law penalizing corrupt election practices should be given a reasonable construction in the interests of the purity of the elections. The resolutions of the Commission on Elections Nos. RR-707 and 731 promulgated respectively on August 13, 1970 and September 17, 1970 are therefore declared illegal and null and void.