Case Digest (G.R. No. 100710)
Facts:
- The case involves two consolidated petitions: G.R. No. 100710 by Benjamin P. Abella and G.R. No. 100739 by Adelina Y. Larrazabal against the Commission on Elections (COMELEC) and Silvestre de la Cruz.
- The petitions arose from the local elections on February 1, 1988, for the governorship of Leyte.
- Adelina Larrazabal filed her certificate of candidacy on January 31, 1988, after her husband, Emeterio V. Larrazabal, was disqualified for lack of residence.
- Larrazabal won the election but was contested by Silvestre de la Cruz, who alleged false statements regarding her residence.
- COMELEC disqualified Larrazabal, citing insufficient residence and registration qualifications.
- Benjamin Abella, the second highest vote-getter, sought to be proclaimed governor following Larrazabal's disqualification.
- The Supreme Court had previously ordered COMELEC to resolve the disqualification case expeditiously.
- COMELEC's final decision on July 18, 1991, affirmed Larrazabal's disqualification and denied Abella's proclamation.
Issue:
- (Unlock)
Ruling:
- The Supreme Court upheld the COMELEC's decision to disqualify Adelina Larrazabal as valid.
- The Court confirmed that COMELEC acted within its jurisdiction regarding the disqualification and the denial of Abella's proclamation.
- The Court supported COMELEC...(Unlock)
Ratio:
- The Supreme Court emphasized the necessity of adhering to legal qualifications for candidates in public office.
- The Court found substantial evidence that Larrazabal was not a resident of Kananga, Leyte, but rather had established her residence in Ormoc City.
- The principle of "animus revertendi," or the intention to return to one's original residence, was highlighted in determining legal residence.
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Case Digest (G.R. No. 100710)
Facts:
The case involves two consolidated petitions: G.R. No. 100710 filed by Benjamin P. Abella and G.R. No. 100739 filed by Adelina Y. Larrazabal against the Commission on Elections (COMELEC) and Silvestre de la Cruz. The events leading to the petitions stem from the local elections held on February 1, 1988, for the governorship of Leyte. Adelina Larrazabal, who was the wife of the disqualified candidate Emeterio V. Larrazabal, filed her certificate of candidacy on January 31, 1988, just a day before the elections, after her husband was disqualified for lack of residence. During the election, Larrazabal received the highest number of votes and was proclaimed the winner. However, her victory was contested by Silvestre de la Cruz, who filed a petition to disqualify her based on alleged false statements regarding her residence in her certificate of candidacy. The COMELEC, after a series of hearings and decisions, ultimately disqualified Larrazabal, stating she lacked the necessary residence and registration qualifications as mandated by the law. Benjamin Abella, who received the second highest number of votes, sought to be proclaimed as governor following Larrazabal's disqualification. The case had previously been elevated to the Supreme Court multiple times, with the Court ordering the COMELEC to resolve the disqualification case expeditiously. The COMELEC's final decision on July 18, 1991, affirmed Larrazabal's disqualification and denied Abella's proclamation as governor, leading to the current petitions.
Issue:
- Who is the rightful go...