Case Digest (G.R. No. 236496) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On November 2, 2021, petitioners Fr. Christian B. Buenafe et al. filed before the Commission on Elections (COMELEC) an Omnibus Election Code Section 78 petition to deny due course to or cancel the Certificate of Candidacy (COC) of respondent Ferdinand R. Marcos, Jr. (Marcos, Jr.) for President. They alleged his COC contained false material representations concerning his eligibility, arguing that a 1997 Court of Appeals (CA) decision in CA-G.R. CR No. 18569—affirming his guilt for failure to file annual income tax returns for taxable years 1982–1985—carried the accessory penalty of perpetual disqualification from public office. On November 20, 2021, petitioners Bonifacio P. Ilagan et al. filed a separate Section 12 petition for disqualification, contending that the same CA decision for failing to file returns also involved moral turpitude and a penalty of imprisonment exceeding eighteen months, grounds for disqualification. Both petitions were consolidated and assailed COMELEC re Case Digest (G.R. No. 236496) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petitioners and their actions
- Buenafe, et al. filed on 2 November 2021 before the COMELEC a Petition to Deny Due Course to or Cancel the COC of respondent Marcos, Jr. under Section 78 of the OEC, alleging false material representations regarding his eligibility and alleged accessory penalty of perpetual disqualification from public office.
- Ilagan, et al. filed on 20 November 2021 before the COMELEC a Petition for Disqualification of respondent Marcos, Jr. under Section 12 of the OEC, alleging he was convicted of a crime involving moral turpitude and sentenced to imprisonment exceeding eighteen months.
- Underlying criminal cases
- In 1995 the RTC convicted Marcos, Jr. for (a) failure to file income tax returns and (b) failure to pay taxes for taxable years 1982–1985, imposing imprisonment and fines.
- On appeal in 1997, the CA acquitted him of failure to pay deficiency taxes, but affirmed his guilt for failure to file returns and imposed only fines:
- P2,000 per year for 1982–1984, plus surcharges
- P30,000 for 1985, plus surcharges
- The CA Decision became final and executory on 31 August 2001.
- COC and COMELEC resolutions
- Marcos, Jr. filed his Certificate of Candidacy for President in October 2021, declaring that he was eligible and had no disqualifying conviction.
- On 17 January 2022 and 10 May 2022, the COMELEC Second Division and En Banc denied Buenafe’s petition for cancellation of COC for lack of merit.
- On 10 February 2022 and 10 May 2022, the COMELEC Former First Division and En Banc dismissed Ilagan’s petition for disqualification for lack of merit.
- Election outcome and national canvass
- National Elections were held on 9 May 2022; Marcos, Jr. secured 31,629,783 votes (58.77%).
- He was proclaimed President-elect on 25 May 2022.
- Buenafe and Ilagan elevated their COMELEC petitions to this Court by Rule 65 certiorari.
Issues:
- Circuit 64 in relation to Rule 65 jurisdiction
- Whether the Supreme Court may review the COMELEC En Banc resolutions denying cancellation of COC and disqualification petitions prior to assumption of office.
- Validity of COMELEC rulings on cancellation of COC (Buenafe)
- Whether respondent Marcos, Jr. committed false material representation in his COC under Section 78 by declaring himself eligible and denying any accessory penalty of perpetual disqualification from public office.
- Whether the penalty of perpetual disqualification was automatically imposed by operation of law in his final judgment of conviction.
- Validity of disqualification petition (Ilagan)
- Whether non-filing of income tax returns and related conviction involves moral turpitude under Section 12 of the OEC.
- Whether respondent was sentenced to imprisonment exceeding eighteen months.
- Whether the CA Decision is void for omitting mandatory penalties.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)