Risos-Vidal v. COMELEC

ATTY. ALICIA RISOS-VIDAL v. COMMISSION ON ELECTIONS and JOSEPH EJERCITO ESTRADA, (D)
G.R. No. 206666, January 21, 2015

FACTS:

• September 12, 2007, the Sandiganbayan convicted former President Estrada, a former President of the Republic of the Philippines, for the crime of plunder.
• October 25, 2007, however, former President Gloria Macapagal Arroyo (former President Arroyo) extended executive clemency, by way of pardon, to former President Estrada.
• October 2, 2012, former President Estrada once more ventured into the political arena, and filed a Certificate of Candidacy, this time vying for a local elective post, that of the Mayor of the City of Manila.
• January 24, 2013, Risos-Vidal, the petitioner in this case, filed a Petition for Disqualification against former President Estrada before the COMELEC. Risos Vidal anchored her petition on the theory that "Former President Estrada is Disqualified to Run for Public Office because of his Conviction for Plunder by the Sandiganbayan Sentencing Him to Suffer the Penalty of Reclusion Perpetua with Perpetual Absolute Disqualification."

ISSUE:

• Whether or not former President Estrada is qualified to vote and be voted for in public office as a result of the pardon granted to him by former President Arroyo.

HELD:

• Yes, former President Estrada is qualified to vote and be voted for in public office as a result of the pardon granted to him by former President Arroyo. It is well-entrenched that where the words of a statute are clear, plain, and free from ambiguity, it must be given its literal meaning and applied without attempted interpretation. Verba legis non est recedendum. From the words of a statute there should be no departure. It is this Court’s firm view that the phrase in the presidential pardon at issue which declares that former President Estrada "is hereby restored to his civil and political rights" substantially complies with the requirement of express restoration.