Title
Arnado vs. Commission on Elections
Case
G.R. No. 210164
Decision Date
Aug 18, 2015
Rommel Arnado, a natural-born Filipino who reacquired citizenship, was disqualified from mayoral races in 2010 and 2013 after using his U.S. passport post-renunciation, violating RA 9225. The Supreme Court upheld his disqualification, prioritizing legal eligibility over voter mandate.

Case Digest (G.R. No. 76647)

Facts:

  • Petitioner’s citizenship journey
    • Rommel C. Arnado was a natural-born Filipino who lost his citizenship upon naturalization as a U.S. citizen.
    • Under RA 9225, he took an Oath of Allegiance to the Republic on July 10, 2008, and the re-acquisition order was issued the same day.
    • He executed an Affidavit of Renunciation of foreign citizenship on April 3, 2009.
    • He was issued a Philippine passport on June 18, 2009 (received September 2009) but used his U.S. passport for earlier 2009 trips.
    • From December 11, 2009 onward, he used his Philippine passport for foreign travel.
  • May 10, 2010 election disqualification (SPA No. 10-109 (DC))
    • Arnado filed his Certificate of Candidacy (CoC) on November 30, 2009, and executed another Renunciation affidavit.
    • Rival candidate Balua filed a disqualification petition; the Comelec First Division disqualified Arnado, but the En Banc reversed on February 2, 2011.
    • This Court’s April 16, 2013 Decision in Maquiling v. Comelec annulled the En Banc ruling, disqualified Arnado for 2010, and declared Maquiling duly elected.
  • May 13, 2013 election and related petitions (SPA No. 13-309 (DC))
    • While Maquiling was pending, Arnado filed his CoC for 2013 on October 1, 2012; Capitan also filed.
    • On May 9, 2013 Arnado executed an Affidavit affirming his April 3, 2009 renunciation.
    • On May 10, 2013 Capitan filed a petition to disqualify Arnado for 2013, but Arnado won the May 13 election with 84% of votes.
    • The Comelec Second Division (September 6, 2013) disqualified Arnado; the Comelec En Banc (December 9, 2013) affirmed and proclaimed Capitan mayor.
    • Arnado then filed this Rule 64/65 certiorari petition with ancillary injunctive relief.

Issues:

  • Procedural challenges
    • Whether the Comelec should have dismissed Capitan’s petitions for forum-shopping or late filing.
    • Whether Commissioner Yusoph’s participation in reviewing his own Second Division decision violated due process.
  • Substantive eligibility questions
    • Whether the Comelec’s disqualification disenfranchised the 84% majority of Kauswagan voters.
    • Whether Arnado had fully complied with RA 9225 before his October 1, 2012 CoC filing and was thus qualified to run.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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