MANILA, Philippines ? Incumbent local officials planning to run again in 2010 may find themselves in a tricky situation upon filing their certificates of candidacy by the end of November, according to the League of Cities of the Philippines.

For instance, Christmas giveaways to their constituents or holiday presents for their godchildren might be construed as ?electioneering,? the LCP said.

?If I gave my ?inaanak? [godchild] P50, I might be accused of vote buying,? LCP president and Mandaluyong Mayor Benhur Abalos said.

In response, the LCP has urged the Commission on Elections to come out with clear guidelines on what constitutes electioneering at the soonest possible time. This way, officials will know what or what not to do during the no-campaigning period, Abalos said.

At a press conference Monday, Abalos noted that the deadline for the filing of certificates of candidacy would fall on November 30, but the actual start of campaigning would begin in March for local officials and February for those seeking a national post.

He said this meant that for at least three months, candidates should not, under the law, do anything that could be construed as campaigning. This, he said, could affect regular services incumbent officials provide their constituents, especially during the Christmas season.

?Incumbent officials will be vulnerable to harassment and accusations of early campaigning,? Abalos said.

He cited as example the usual practice in Mandaluyong City of giving away 30,000 to 40,000 packs of goods to residents during Christmas, but the tradition could be construed as early campaigning on his part.

In the past, the deadline for the filing of candidacy usually fell on a February or March, but this year, the Comelec decided to have the certificates of candidacy in, three months early, to have enough time to print out the special ballots for the automated elections, Abalos said.