What their guidelines prohibit, he pointed out, is turning the graduation rite as a political forum or platform.
"Pag-uusapan namin 'yan dahil, obviously, it's not a political activity (graduation rites). It is not meant directly to ask for the vote of a person. Pero kung mauwi sa ganun ay 'yun ang pinagbabawal," Malaluan said.
"Malinaw naman kasi sa kanilang (Comelec) guidelines what constitutes electioneering. Kung hindi naman ginagamit bilang isang partisan political activity ang graduation, halimbawa ang isang kandidato ay magpapahayag lamang tungkol sa graduation or some issues, hindi naman puwedeng sabihin siguro na electioneering 'yun," he added.
Considered electioneering, according to Malaluan, is holding political caucuses, conferences, meetings, rallies, parades, or other similar assemblies for the purpose of soliciting votes and undertaking a campaign for or against a candidate or party.
Making speeches, announcements or commentaries or holding interviews for or against the election of any candidate or party for public office, directly or indirectly soliciting votes, pledges or support for or against any candidate or party is also an act of electioneering, he added.
"Ang isang graduation naman ay maaaring ganapin that will not involve those actions even if the guest is a candidate. That includes in the awareness of a candidate," Malaluan said.
"But if it does not generate into a solicitation of votes, then you could not include it as an electioneering activity," he added.
In case an act of electioneering occurs during a graduation rite, Malaluan said the school and its officials may face administrative sanctions.
"Our administrative provisions will follow except that ito nga, kapag may electioneering activity, meron ding sanctions itong Comelec itself because it's under the jurisdiction of Comelec," he said.
The 90-day official campaign period for senatorial and party-list candidates in the 2019 elections began on February 12, while that for candidates for district representatives and local government on March 29, 2019.
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