Is the failure to place the punctuation mark comma (,) to separate the geographic locations in a residential address a basis for disqualification of a candidate for material misrepresentation in his or her certificate of candidacy (COC)?

No, the Supreme Court (SC) said as it pointed out that the missing comma that was the basis for the Commission on Elections (Comelec) to disqualify a candidate is an “overly literal and narrow interpretation” of what amounts to a material misrepresentation.

In a decision written by Associate Justice Ramon Paul L. Hernando, the SC granted the petition of Errol B. Comafay Jr. who challenged the Comelec’s ruling that disqualified him as a candidate for councilor in Tabuk City in Kalinga province in the 2025 local and national elections.

Published news reports stated that in the 2025 election in Tabuk City, Comafay – a lawyer and a teacher – topped the election for city council members with 41,582 votes.

The same reports stated that he was not proclaimed due to the Comelec’s disqualification ruling.

A copy of the SC decision has not been made public by the SC which provided a summary through its Office of the Spokesperson.

The summary stated that the Comelec cancelled Comafay’s COC for misrepresenting his residential address. The poll body granted the petition filed by Paquinto Sallaya.

In his COC, Comafay wrote his address as “TARAKI NATIONAL RD PUROK 5,” without a comma. In another part of the COC, he wrote his address as “TARAKI, NATIONAL RD, PUROK 5, BRGY. BULANAO, TABUK CITY, KALINGA,” with commas separating the geographic locations.

In his petition to cancel Comafay’s COC, Sallaya told the Comelec that there was misrepresentation because no “Taraki National Road” existed in Barangay Bulanao or anywhere in Tabuk City.

Comafay denied Sallaya’s allegation and pointed out that he had no intent to deceive the voters when he stated his address in his COC.

He submitted documents such as his Unified Multi-purpose ID, his COC for the elections, Personal Data Sheet, and Statement of Assets, Liabilities and Net Worth.

The Comelec’s second division granted Sallaya’s petition and held that the lack of a comma in Comafay’s stated address amounted to a material misrepresentation.

It ruled that Comafay deliberately misled both the Comelec and the voters by providing a false address. The division ruling was affirmed by the Comelec as a full commission.

Comafay elevated the issue before the SC.

Granting Comafay’s petition, the SC ruled that the omission of a comma in his residential address does not amount to a material misrepresentation in his COC.

It pointed out that under Section 78 of the Omnibus Election Code, a petition to deny due course or cancel COC may be granted only upon clear proof that a candidate made a false material representation regarding qualifications such as residency, age, or citizenship, and to justify the cancellation, the misrepresentation must be both material and false.

The SC explained that the misrepresentation is material if it concerns the candidate’s qualifications for office, and false if the candidate knowingly and deliberately made the untrue statement with intent to deceive the Comelec or the voters.

It stressed that in the case of Comafay’s disqualification, the missing comma did not affect his qualifications as it pointed out that the omission was harmless because it did not change the meaning of the address or relate to his qualifications.

Thus, the SC said there was no bad faith on the part of Comafay, who stated in the same document his address with the comma. It said that he had also consistently used “Taraki, National Rd, Brgy. Bulanao, Tabuk City” in almost all his transactions, legal documents, and identification cards for more than a decade.