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Missing ‘comma’ does not amount to material misrepresentation — SC

Manila Bulletin

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January 17, 2026

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)?

- By REY G. PANALIGAN

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.

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