The Supreme Court said it is mandatory for candidates to submit within the 30-day period after the national and local elections the complete Statement of Contributions and Expenditures.

In a 19-page ruling penned by Associate Justice Mario Lopez, the Court en banc declared as void Resolution No. 10147 issued by the Commission on Elections on 23 June 2016, extending the filing of SOCEs until 30 June 2016 from 8 June 2016.

The court held that the Comelec committed grave abuse of discretion in issuing the said resolution.

"The arbitrary extension of the deadline for the submission of the SOCEs effectively condoned erring candidates and political parties from administrative liabilities even if the law does not provide any exempting circumstances," the SC declared.

The poll body's blanket extension of the period to file SOCEs "amounts to usurpation of legislative power," it added.

The Court, though, said the SOCEs submitted within the extended deadline set under Comelec Resolution 10147 are deemed "timely filed" based on the doctrine of operative fact, which recognizes the effects of the law or executive issuance prior to its invalidation when relied upon by the public in good faith.

"Here, the candidates and political parties that submitted their SOCEs following the extended deadline acted in good faith. They honestly believed on the resolution that was issued pursuant to the COMELEC's rule-making authority," the SC said.

The SC noted that the Comelec even previously extended the deadline for the filing of SOCES in the 2010 and 2013 national and local elections, which were not questioned until the present case.

"Accordingly, the effects of accomplished acts prior to the invalidation of Comelec Resolution No. 10147 should be allowed to stand. The SOCEs submitted within the extended period or until June 30, 2016 are deemed timely filed," the Court explained.

The SC's decision was borne out of the petition filed by the Partido Demokratiko Pilipino-Lakas ng Bayan on 7 July 2016 questioning the validity of Comelec Resolution No. 10147.

It argued that the Comelec exceeded the limits of its delegated rule-making authority and violated Section 14 of R.A. 7166 (An Act Providing for Synchronized National and Local Elections…) that the SOCE must be filed within 30 days after the elections.

The party argued that the Comelec should have retained the original deadline to avoid perceptions of partiality given that other candidates and political parties had promptly complied with the requirement.

The poll body argued that the law providing that "no person elected to any public office shall enter upon the duties of his office until he has filed the statement of contributions and expenditures herein required" implied that the SOCEs may be submitted beyond the 30-day period.

It added that it previously allowed extension of time in filing the SOCEs due to legal necessity and to prevent a vacuum in the public service.

The SC, however, said this interpretation was incorrect. Legislative deliberations, according to the court, revealed that winning candidates must submit the SOCEs before assumption of office.

"Taken together, the COMELEC issued Resolution No. 1O147 with grave abuse of discretion which is arbitrary, capricious, whimsical, or despotic exercise of judgment as when the assailed resolution is bereft of any factual and legal justification, or when the disputed act of the tribunal goes beyond the limits of discretion thus effecting an injustice," the court said.