G.R. No. 258456 - Aggabao vs. Commission on Elections

On October 4, 2021, Amelita S. Navarro (Navarro) filed her Certificate of Candidacy (COC) for Mayor of Santiago City, Isabela, with a notarized Certificate of Nomination and Acceptance (CONA) dated September 23, 2021, signed by Senator Panfilo M. Lacson (Sen. Lacson) as Partido Reporma’s official endorsement.
On October 8, 2021, Christopher G. Ayson (Ayson) similarly filed a COC for the same position, attaching a CONA of even date likewise signed by Sen. Lacson.

On November 6, 2021, Sen. Lacson sent a letter and notarized certification to COMELEC’s Law Department disclaiming any CONA issued to Ayson and affirming Navarro as the sole Partido Reporma nominee for mayor.
On November 9, 2021, Navarro withdrew her COC for Mayor and filed a new COC for Vice-Mayor; on the same day, Giorgidi B. Aggabao (Aggabao) filed a COC as her substitute, supported by a CONA dated November 8, 2021 signed by Sen. Lacson.

Document No. 21-3973 (November 10, 2021): Declared Navarro (and Ayson) independent candidates under Section 15 of COMELEC Resolution 10717 for multiple nominations by one party.
Document No. 21-7467 (December 22, 2021): Withdrew Navarro’s COC as Mayor and denied due course to Aggabao’s substitution, citing Section 15.
Document No. 22-0176 (January 5, 2022): Denied Aggabao’s motion for reconsideration, reiterating Navarro’s independent status and disallowing substitution for independent candidates.

Aggabao and Navarro filed a Petition for Certiorari (Rule 64) alleging grave abuse of discretion and due process violations; they sought nullification of the three COMELEC issuances and a restraining order.
On January 25, 2022, the Supreme Court issued a Temporary Restraining Order (TRO) enjoining enforcement of Document No. 21-7467; COMELEC did not comply due to ballot‐printing timelines.

Did COMELEC gravely abuse its discretion by declaring Navarro (and Ayson) independent candidates despite Sen. Lacson’s disavowal of Ayson’s CONA?
Did COMELEC violate due process and its quasi-judicial obligations by denying due course to Aggabao’s substitution without notice and hearing?

When must COMELEC exercise administrative (ministerial) functions versus quasi-judicial functions requiring notice and hearing?
What is the proper remedy for denial of hearing in COMELEC’s adjudication of candidate qualifications and substitutions?