In his first financial filing as a presidential candidate, former religious broadcaster Marion G. (Pat) Robertson reported yesterday that he has spent the most of any 1988 candidate -- $11 million. But he didn't clear up questions about whether he used the resources of his Christian Broadcasting Network to raise the funds.

R. Marc Nuttle, Robertson's campaign manager, told reporters yesterday that the candidate did not use mailing lists from CBN in raising $11 million from more than 120,000 donors.

Other participants in the Robertson effort said, however, that the campaign did use CBN mailing lists in raising money last year, as part of a drive to get 3 million signatures urging the television evangelist to run for president.

The issue of the Robertson campaign's relationship with CBN is sensitive in light of an audit that the Internal Revenue Service has been conducting of CBN and its donations of millions of dollars to the Freedom Council, another group with a tax exemption that sponsored several Robertson rallies in Michigan last year. Tax-exempt funds cannot be used for partisan political purposes.

Nuttle said at a news conference that the Robertson fund-raising effort shows the candidate has a nationwide grass-roots organization that is "ready to compete with anybody, everywhere for every delegate." Nuttle said the Robertson campaign will now use the names collected in its drive for signatures to raise money for the presidential race. He said Robertson hopes to have a mailing list of 7 million supporters by the end of this year.

Robertson's 4,922-page filing at the Federal Election Commission listed the names of more than 20,000 donors who gave $200 or more. Only about 600 donors gave the maximum $1,000 to the campaign. The campaign had $233,480 in the bank as of Sept. 30, but had debts of $814,000.

In comparison, Vice President Bush, the only candidate who has raised more than Robertson -- $12.6 million -- has $4.8 million in cash and debts of $325,000, according to his campaign.

Nuttle said yesterday that the CBN board of directors -- which includes Robertson's wife -- refused as recently as August to rent the campaign committee the hundreds of thousands of names of donors who have made CBN a $180-million-a-year business. CBN did so, Nuttle said, to keep the campaign "at arm's length" and to make sure it did nothing to jeopardize its tax-exempt status. Joseph Gray, spokesman for the network, said yesterday it is CBN practice not to rent out its mailing list.

David West, who was spokesman for the exploratory committee, Americans for Robertson, last fall, said then that the network, which Robertson headed until his formal announcement Oct. 1, rented its mailing list to an Arizona firm called Victory Communications to start a drive to get 3 million voters to back a Robertson candicacy.

Michael Clifford, head of Victory Communications, said yesterday, "I won't dispute that." He said the lists were turned over to the campaign after he was paid for putting on the satellite-television event that kicked off the petition drive.

Constance Snapp, Robertson's press secretary, said yesterday that the kickoff event cost $1.2 million and that more than $5 million was raised during the subsequent 30 days.

When asked about the Victory-CBN relationship, Snapp said Nuttle should have said he didn't know for sure whether CBN lists were used because Victory and another company got the lists themselves. She said Robertson told her he didn't know whether CBN lists had been used.

Robertson cut his ties to CBN and resigned his Baptist ministry ordination when he officially became a candidate two weeks ago, Nuttle said yesterday, because he felt the concept of separation of church and state was so important "he wouldn't even give the appearance those lines were blurred."

Asked why the campaign tried to rent the CBN list at all, Snapp said it was strictly a business decision.

Officials from the Freedom Council, which was closed abruptly last October just as the IRS audit was starting, have said that CBN furnished as much as $250,000 a month during 1985 and 1986 to fund its work of getting Christians involved in politics.

The CBN tax return for the year ending March 31, 1985, for example, showed the network loaning $821,000 to the council. The CBN return for the following year reported giving more than $4.6 million to two arms of the Freedom Council. CBN spokesman Gray said yesterday that the loan became a grant later last year because the Freedom Council went out of business.

Asked why Robertson was the only presidential candidate for which the Freedom Council sponsored events in Michigan, Nuttle said, "No one else asked."

All the declared presidential candidates filed financial reports yesterday with the FEC. According to those reports, Gov. Michael S. Dukakis (D-Mass.) continued to lead the Democratic pack in fund-raising. He raised $3.5 million in the quarter ending Sept. 30, bringing his total thus far to $8.1 million. Dukakis reported having $4.3 million in cash on hand.

The campaign of Sen. Robert J. Dole (R-Kan.) reported raising nearly $4 million in the last quarter for a total of almost $8 million thus far. Dole has $2.2 million on hand and debts of about $500,000, his report said.

Rep. Jack Kemp (R-N.Y.) reported doing much less well. He raised $2.8 million in the latest quarter, bringing his total to $6.3 million, but reported cash on hand of $407,000, and debts of $882,000. Political researcher Colette Rhoney contributed to this report.