EXHIBIT 31.2

CERTIFICATION OF EXECUTIVE VICE PRESIDENT AND SECRETARY PURSUANT TO RULE
13(a)-14(a)/15d-14(a) OF THE SECURITIES EXCHANGE ACT OF 1934, AS ADOPTED
PURSUANT TO SECTION 302 OF THE SARBANES-OXLEY ACT OF 2002

I, Edward A. Machulak, certify that:

1.   I have reviewed this annual report on Form 10-K of Commerce Group
     Corp.;

2.   Based on my knowledge, this report does not contain any untrue
     statement of a material fact or omit to state a material fact
     necessary to make the statements made, in light of the circumstances
     under which such statements were made, not misleading with respect
     to the period covered by this report;

3.   Based on my knowledge, the financial statements, and other financial
     information included in this report, fairly present in all material
     respects the financial condition, results of operations and cash
     flows of the registrant as of, and for, the period presented in this
     report;

4.   The registrant's other certifying officer(s) and I are responsible
     for establishing and maintaining disclosure controls and procedures
     (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) for the
     registrant and internal control over financial reporting (as defined
     in Exchange Act Rules 13a-15(f) and 15d-15(f) for the registrant and
     have:

     a)  Designed such disclosure controls and procedures, or caused such
         disclosure controls and procedures to be designed under our
         supervision, to ensure that material information relating to the
         registrant, including its consolidated subsidiaries, is made
         known to us by others within those entities, particularly during
         the period in which this report is being prepared;

     b)  Evaluated the effectiveness of the registrant's disclosure
         controls and procedures and presented in this report our
         conclusions about the effectiveness of the disclosure controls
         and procedures, as of the end of the period covered by this
         report based on such evaluation; and

     c)  Disclosed in this report any change in the registrant's internal
         control over financial reporting that occurred during the
         registrant's fourth quarter that has materially affected, or is
         reasonably likely to materially affect, the registrant's
         internal control over financial reporting; and

5.   The registrant's other certifying officer(s) and I have disclosed,
     based on our most recent evaluation of internal control over
     financial reporting, to the registrant's auditors and the audit
     committee of the registrant's board of directors (or persons
     performing the equivalent functions):

     a)  all significant deficiencies and material weaknesses in the
         design or operation of internal control over financial reporting
         which are reasonably likely to adversely affect the registrant's
         ability to record, process, summarize and report financial
         information; and

     b)  any fraud, whether or not material, that involves management or
         other employees who have a significant role in the registrant's
         internal control over financial reporting.

Date:  June 27, 2006                /s/ Edward A. Machulak
                                    -------------------------
                                    Edward A. Machulak
                                    Executive Vice President,
                                    and Secretary