Guidelines for Understanding, Adjudicating, and Resolving Disputes in Elections three members of COMELEC to be non-lawyers, but in practice only lawyers are appointed. All of the present member of COMELEC are lawyers, three of whom are retired jurists. COMELEC operates from its central office in Manila, but it has offices in all municipalities, cities and provinces. Notwithstanding its nationwide presence, COMELEC decides election matters centrally at its Manila office. C. Types of Election Complaints in the Philippines Election protests are not the only election complaints that occur in the Philippines. Election complaints in the Philippines may be classified into: (1) those relating to the right to vote and voter registration; (2) those relating to the qualification of candidates and of political parties; (3) those relating to the conduct of an election; (4) those involving criminal violations of election laws; and (5) those relating to the integrity of election results. Complaints related to the right to vote are considered judicial issues and hence taken cognizance of, and resolved, by judicial authorities. Under the Philippine Voter Registration Law,24 the first level courts hear petitions for inclusion or exclusion of voters in the registry list of voters. A citizen’s application for registration as a voter is actually heard at the first instance by a body in each municipality called the Election Registration Board (ERB).25 As it is the action of the ERB which can be questioned before the courts,26 the cause of action for inclusion or exclusion of voter arises only after an applicant for registration is either wrongly included or wrongly excluded in the voters’ registry list. COMELEC, on the other hand, has jurisdiction over issues concerning candidate qualification and political party registration, as well as those related to the conduct of elections.27 COMELEC’s jurisdiction under these types of complaints includes deciding whether a candidate should be disqualified for violation of conduct required of a candidate.28 Voter Registration Act, Rep. Act 8189 (1996). Id., §§ 32-35. 26 Id., § 17. 27 Const., Art. IX-C, sec. 2(3) (Phil.). 28 For instance, the acts enumerated in Section 68 of the Batas Pambansa Blg. 881 (Omnibus Election Code) can lead to the administrative disqualification of a candidate from continuing his or her candidacy, without prejudice to possible criminal prosecution. 24 25 184