Case Digest (G.R. No. 258456)
Facts:
The case involves Giorgidi B. Aggabao and Amelita S. Navarro as petitioners against the Commission on Elections (COMELEC) and its Law Department as respondents. The events leading to this case began when Navarro filed her Certificate of Candidacy (COC) for Mayor of Santiago City, Isabela, on October 4, 2021, claiming to be the official candidate of the Partido para sa Demokratikong Reporma (Partido Reporma). She attached a notarized Certificate of Nomination and Acceptance (CONA) signed by Senator Panfilo M. Lacson, the party chairperson. Shortly after, on October 8, 2021, Christopher G. Ayson also filed a COC for the same position, claiming to have a CONA from the same party. Upon learning of Ayson's claim, Senator Lacson sent a letter to COMELEC on November 6, 2021, disavowing Ayson's CONA and affirming Navarro as the official candidate of the party.
On November 9, 2021, Navarro withdrew her candidacy for Mayor and opted to run for Vice Mayor, stating that Aggabao...
Case Digest (G.R. No. 258456)
Facts:
Filing of Certificates of Candidacy (COCs):
- On October 4, 2021, Amelita S. Navarro filed her COC for Mayor of Santiago City, Isabela, under the Partido para sa Demokratikong Reporma (Partido Reporma), attaching a notarized Certificate of Nomination and Acceptance (CONA) signed by Senator Panfilo M. Lacson, the party's Chairperson.
- On October 8, 2021, Christopher G. Ayson also filed a COC for the same position, claiming nomination from Partido Reporma and submitting a CONA allegedly signed by Senator Lacson.
Disavowal of Ayson's Nomination:
- On November 6, 2021, Senator Lacson sent a letter to the COMELEC Law Department, disclaiming any CONA issued to Ayson and affirming Navarro as the official candidate of Partido Reporma for Mayor of Santiago City, Isabela.
- A notarized certification from Senator Lacson was attached, stating that Partido Reporma did not issue any CONA to Ayson.
Withdrawal of Navarro and Substitution by Aggabao:
- On November 9, 2021, Navarro withdrew her candidacy for Mayor and filed a COC for Vice-Mayor, stating that she would be substituted by Giorgidi B. Aggabao, also a member of Partido Reporma.
- Aggabao filed his COC for Mayor on the same day, attaching a CONA dated November 8, 2021, signed by Senator Lacson.
COMELEC's Dispositions:
- On November 10, 2021, the COMELEC issued Document No. 21-3973, declaring Navarro an independent candidate under Section 15 of COMELEC Resolution No. 10717, which prohibits a party from nominating more than one candidate for a single position.
- On December 22, 2021, the COMELEC issued Document No. 21-7467, denying Aggabao's COC as a substitute candidate, maintaining that Navarro was an independent candidate.
- On January 5, 2022, the COMELEC issued Document No. 22-0176, denying Aggabao's motion for reconsideration, reiterating that both Ayson and Navarro were independent candidates.
Certified List of Candidates:
- On December 23, 2021, the COMELEC posted the Certified List of Candidates for the May 9, 2022 elections. Navarro was listed as a candidate for Vice-Mayor under Partido Reporma, while Ayson was listed as an independent candidate for Mayor. Aggabao's name was excluded from the list of Mayoral candidates.
Issue:
Due Process Violation:
- Petitioners argue that the COMELEC violated their right to due process by denying Aggabao's COC as a substitute candidate without prior proceedings before any of its Divisions.
Misapplication of Section 15 of COMELEC Resolution No. 10717:
- Petitioners contend that the COMELEC incorrectly applied Section 15, as Partido Reporma did not nominate more than one candidate for Mayor. Ayson's CONA was fake, as repeatedly disavowed by Senator Lacson.
Grave Abuse of Discretion:
- Petitioners assert that the COMELEC committed grave abuse of discretion in declaring Navarro an independent candidate and denying Aggabao's substitution, despite evidence that Ayson's CONA was fraudulent.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)