Case Digest (G.R. No. L-20751) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Rogelio Batin Caballero and Jonathan Enrique V. Nanud, Jr. were rival candidates for Mayor of Uyugan, Batanes in the May 13, 2013 elections. Caballero filed his Certificate of Candidacy (COC) on October 3, 2012, declaring himself a Filipino citizen and resident of Barangay Imnajbu, Uyugan for at least one year prior to the election. Nanud filed a verified petition before the COMELEC First Division on December 3, 2012 to deny due course to or cancel the COC, alleging Caballero’s Canadian naturalization and nonresidency rendered his COC false. Caballero did not file a formal answer but submitted a memorandum arguing that he had validly reacquired Philippine citizenship under Republic Act No. 9225 by taking his Oath of Allegiance on September 13, 2012 in Toronto and renouncing Canadian citizenship on October 1, 2012 in Batanes, and maintained his domicile of origin in Uyugan despite work stints abroad. On May 3, 2013 the COMELEC First Division found a material misrepresentation, ca Case Digest (G.R. No. L-20751) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and candidacies
- Rogelio Batin Caballero – natural-born Filipino, later Canadian citizen, filed Certificate of Candidacy (COC) for Mayor of Uyugan, Batanes in the May 13, 2013 elections.
- Jonathan Enrique V. Nanud, Jr. – rival candidate; filed petition before the COMELEC to cancel Caballero’s COC.
- Petition to cancel COC and service issues
- Nanud alleged Caballero falsely declared one–year residency in Uyugan and concealed his Canadian citizenship in his COC.
- Service: petition sent by registered mail to Caballero’s Philippine address; Caballero claimed improper service but received the petition at the December 10, 2012 conference. He did not file a formal answer but submitted a memorandum.
- Citizenship reacquisition and renunciation
- Caballero took Oath of Allegiance under RA 9225 before the Philippine Consul General in Toronto on September 13, 2012, thus reacquiring Philippine citizenship while retaining Canadian citizenship.
- He executed an Affidavit of Renunciation of Canadian citizenship on October 1, 2012 in Batanes.
- COMELEC First Division resolution
- May 3, 2013 – COMELEC First Division cancelled Caballero’s COC for material misrepresentation, finding that naturalization abroad abandoned his domicile and that he failed to reestablish one–year residency.
- Elections held May 13, 2013; Caballero initially proclaimed Mayor; Nanud filed motions to defer and annul proclamation.
- Proceedings before COMELEC En Banc and Supreme Court
- Caballero’s Motion for Reconsideration denied by COMELEC En Banc on November 6, 2013.
- Caballero filed a Rule 65 certiorari petition with the Supreme Court, challenging procedural service, domicile abandonment, and the one–year residency requirement.
Issues:
- Whether the COMELEC gravely abused its discretion by accepting and deciding Nanud’s petition despite imperfect service.
- Whether Caballero abandoned his Philippine domicile when he naturalized as a Canadian citizen.
- Whether Caballero’s reacquisition of Filipino citizenship and nine months’ physical stay before elections constituted substantial compliance with the one–year residency requirement.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)