CRISTOBAL vs.

LABRADOR

Santos was convicted of the crime of estafa. He was given pardon by the president but even
prior to his pardon he was already holding the position as the municipality president of
Malabon notwithstanding his conviction.
Cristobal, on the other hand, averred that Santos should be excluded from the list of electors
in Malabon because he was already convicted of final judgment for any crime against
property. This is pursuant to CA 357 of the New Election Code. The lower court presided by
Labrador ruled that Santos is exempt from the provision of the law by virtue of the pardon
restoring the respondent to his full civil and political rights, except that with respect to the
right to hold public office or employment, he will be eligible for appointment only to
positions which are clerical or manual in nature and involving no money or property
responsibility.

ISSUE: Whether or not Santos should not be excluded as an elector.

RULING: YES. It should be observed that there are two limitations upon the exercise of this
constitutional prerogative by the Chief Executive, namely: (a) that the power be exercised after
conviction; and (b) that such power does not extend cases of impeachment. Subject to the
limitations imposed by the Constitution, the pardoning power cannot be restricted or controlled by
legislative action. It must remain where the sovereign authority has placed it and must be exercised
by the highest authority to whom it is entrusted. An absolute pardon not only blots out the crime
committed, but removes all disabilities resulting from the conviction.