Title
Co vs. Commission on Elections
Case
G.R. No. L-26959
Decision Date
Jul 21, 1967
Oscar V. Co challenged his reassignment as election registrar, claiming it violated his security of tenure. The Supreme Court ruled that his initial appointment lacked a specific station, thus no vested right to Agoo, La Union, existed.
A

Case Digest (G.R. No. L-26959)

Facts:

  • Parties and nature of the case
    • Oscar V. Co (petitioner) filed a petition for certiorari, prohibition, mandamus and quo warranto, with a prayer for preliminary injunction.
    • The respondents were the Commission on Elections (COMELEC), Abelardo Subido, as Commissioner of Civil Service, and Cecilio O. Estoesta, as Election Registrar of the COMELEC.
    • The dispute involved the office of municipal election registrar for Agoo, La Union.
    • The petitioner claimed entitlement to the Agoo, La Union position and prayed that the respondent be excluded from it.
  • Petitioner’s initial appointment and subsequent assignments
    • On November 2, 1964, the COMELEC extended to the petitioner a provisional appointment as “Election Registrar of the Commission on Elections,” without statement of any specific official station.
    • On November 9, 1964, by telegram-directive, the petitioner was directed to “report and assume duty as election registrar for the municipality of Agoo, province of La Union,” and he did so.
    • The petitioner served as election registrar for Agoo, La Union until September 6, 1966.
  • Petitioner’s permanent appointment to a different station
    • On September 6, 1966, the petitioner was extended a permanent appointment as “Election Registrar in the Commission on Elections for Sabangan, Mountain Province,” and he was directed to immediately proceed to his new station.
  • Respondent’s appointment and certification
    • On September 7, 1966, the respondent Cecilio O. Estoesta was appointed “Election Registrar in the Commission on Elections for Agoo, La Union.”
    • ...(Subscriber-Only)

Issues:

  • Core issue
    • Whether, under the circumstances, the appointment of the petitioner as election registrar for Sabangan, Mountain Province trenched upon the petitioner’s right to security of te...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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