Facts:

The case Rommel C. Arnado vs. Commission on Elections and Florante Capitan (G.R. No. 210164, August 18, 2015) involves the disqualification of Rommel C. Arnado from running for the mayoralty of Kauswagan, Lanao del Norte during the May 13, 2013 elections. Arnado, a natural-born Filipino, had lost his Philippine citizenship after becoming a naturalized citizen of the United States. He applied for repatriation under Republic Act No. 9225 and took an Oath of Allegiance to the Republic of the Philippines on July 10, 2008, following which he received an Order of Approval for Citizenship Retention and Re-acquisition. On April 3, 2009, Arnado executed an Affidavit of Renunciation of his foreign citizenship. Despite this, he continued using his US passport, leading Linog C. Balua—a rival mayoralty candidate—to petition the Commission on Elections (Comelec) to disqualify him, arguing that such usage implied he had not effectively renounced his US citizenship.

Arnado garnered the highest

Facts:

Rommel C. Arnado, a natural‐born Filipino who had lost his Philippine citizenship upon naturalization as a U.S. citizen, subsequently sought to reacquire his Filipino citizenship under Republic Act No. 9225. In compliance, he took an Oath of Allegiance and executed an Affidavit of Renunciation of his U.S. citizenship. However, after executing the April 3, 2009 Affidavit of Renunciation, Arnado continued using his U.S. passport for travel—an act later held in the earlier Maquiling case to “recant” or nullify his express renunciation. Despite re‐acquisition procedures, he filed his Certificate of Candidacy (CoC) for the mayoralty post of Kauswagan, Lanao del Norte, on October 1, 2012 without submitting a timely new oath renouncing his U.S. citizenship. During the May 2013 elections he won overwhelmingly—garnering 84% of the votes—but his proclamation was later set aside by the Commission on Elections (Comelec) on the ground that, based on the prior Maquiling decision, his subsequent acts (i.e. continued use of his U.S. passport) effectively meant that he had not complied with the strict requirement under RA 9225 to make a personal and sworn renunciation of any foreign citizenship at or before the time of filing his CoC.

Issue:

1. Whether the Comelec (both its Second Division and En Banc) acted with grave abuse of discretion by denying Arnado relief and by considering his later affidavit (filed after his CoC) untimely, despite his claim that he had complied with RA 9225.
2. Whether procedural due process was violated when the petitions filed against Arnado were not dismissed on grounds of forum shopping or late filing.
3. Whether the use of a foreign passport after executing a renunciation affidavit effectively “recanted” the renunciation, thereby disqualifying a candidate under Section 40(d) of the Local Government Code.
4. Whether the overwhelming vote of the electorate may cure or override a defect in a candidate’s qualification.

Ruling:

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Ratio:

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Doctrine:

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