Facts:

In the case of Roberto AlbaAa, Katherine Belo, Generoso Derramas, and others as petitioners against the Commission on Elections (COMELEC) and private respondents, the controversy revolves around the May 14, 2001 elections in Panitan, Capiz, where the petitioners were proclaimed duly elected municipal officials. Specifically, Roberto AlbaAa was proclaimed Mayor; Katherine Belo, Vice-Mayor; and several others were proclaimed members of the Sangguniang Bayan. Subsequent to these elections, on June 23, 2001, private respondents filed a complaint against the petitioners with the COMELEC, alleging election offenses including terrorism and vote-buying under the Omnibus Election Code.

The Law Department of the COMELEC found prima facie evidence and recommended the filing of an Information against the petitioners for the alleged election offenses, alongside a disqualification from holding office. On February 28, 2003, the COMELEC En Banc directed the filing of the necessary Information

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Facts:

Procedural Background

• The petitioners – Roberto Albaaa, Katherine Belo, Generoso Derramas, Vicente Duran, Ricardo Araque, Lilia Aranas, Merlinda Degala, Gabriel Aranas, Ernesto Bito-on, and Juvic Deslate – were proclaimed winners in the May 14, 2001 elections for various municipal positions (Mayor, Vice-Mayor, and Members of the Sangguniang Bayan) in Panitan, Capiz.
• The private respondents, who participated as candidates in the same elections, later alleged that the petitioners committed election offenses, including acts of terrorism and vote-buying, under Sections 261(e) and 261(a) of the Omnibus Election Code, respectively.

Initiation of Disqualification Proceedings

• On June 23, 2001, the private respondents filed a complaint with the COMELEC Law Department alleging electoral offenses by the petitioners and seeking their disqualification.
• The Law Department found a prima facie case and, on January 15, 2002, issued a resolution recommending the filing of an Information against the petitioners and the disqualification of all of them from holding office.

COMELEC’s Actions and Resolutions

• Acting on the Law Department’s recommendation, the COMELEC En Banc on February 28, 2003, directed its Law Department to file the appropriate Information and instructed the Clerk of the Commission to docket the case as a disqualification case.
• The petitioners subsequently filed a motion for reconsideration, alleging that COMELEC’s resolution lacked findings of fact and improperly examined the merits of the evidence. They also contended that the docketing of the disqualification complaint was procedurally erroneous given the applicable COMELEC Resolution No. 2050.
• On June 3, 2003, COMELEC denied the petitioners’ motion for reconsideration due to lack of merit and untimeliness, and the disqualification case was docketed as SPA No. 03-006.
• On October 21, 2003, the COMELEC First Division issued a resolution annulling the petitioners’ proclamation on the ground that they violated Sections 261(a) and (e) of the Omnibus Election Code, and ordered the election officer to constitute a new Municipal Board of Canvassers.

Subsequent Developments

• The petitioners’ motions for reconsideration and supplements were later denied by the COMELEC En Banc in its resolution dated May 5, 2004, which also declared them disqualified and deemed their votes stray.
• On May 13, 2004, the petitioners filed a Petition for Certiorari and Prohibition with an application for a Temporary Restraining Order (TRO) aimed at nullifying the controversial COMELEC resolutions.
• Despite the petitioners’ plea for a TRO, the Court did not issue such order, leading COMELEC to declare its resolutions final and executory, with the Regional Election Director directed to implement them on May 27, 2004.
• On June 10, 2004, the Municipal Board of Canvassers subsequently proclaimed the private respondents as the winners for the respective positions in Panitan, Capiz.

Issue:

Mootness of the Petition

• Whether the petition for nullification of COMELEC resolutions became moot owing to the election and proclamation of a new set of municipal officials after the May 10, 2004 elections.
• Whether, despite the mootness, the case should be resolved to prevent future recurrences of similar issues.

Abuse of Discretion by the COMELEC

• Whether the COMELEC committed grave abuse of discretion amounting to lack or excess of jurisdiction when it issued its resolutions disqualifying the petitioners who had already been proclaimed winners.
• Whether the COMELEC’s actions violated Section 2 of COMELEC Resolution No. 2050, which mandates dismissal of a disqualification complaint for a candidate already proclaimed as winner, with the complaint merely referred for preliminary investigation.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)