Case Digest (G.R. No. 207059) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the consolidated petitions Co vs. HRET (G.R. Nos. 92191-92) and Balanquit vs. HRET (G.R. Nos. 92202-03), the petitioners Antonio Y. Co and Sixto T. Balanquit, Jr. challenged the House of Representatives Electoral Tribunal’s (HRET) November 6, 1989 decision and its February 22, 1990 resolution denying reconsideration. The HRET had upheld respondent Jose Ong, Jr.’s proclamation as the duly elected Representative of the Second District of Northern Samar in the May 11, 1987 congressional elections, finding him to be a natural-born Filipino citizen and a legal resident of Laoang, Northern Samar for the one-year period immediately preceding the election. Petitioners lodged election protests on grounds that Ong was neither a natural-born citizen nor a district resident. After the HRET dismissed those protests, they filed these petitions for certiorari and mandamus with the Supreme Court, contending that the tribunal acted with grave abuse of discretion in making its determinations. Case Digest (G.R. No. 207059) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Congressional election and protests
- On May 11, 1987, the second-district race in Northern Samar featured petitioners Antonio Y. Co and Sixto T. Balanquit, Jr., and private respondent Jose Ong, Jr.
- Ong, Jr. was proclaimed winner; petitioners filed protests alleging he was not a natural-born citizen and not a one-year resident of the district.
- HRET proceedings
- On November 6, 1989, the House Electoral Tribunal (HRET) held that Ong, Jr. is a natural-born Filipino citizen and a Laoang resident.
- Petitioners’ motion for reconsideration (filed November 12, 1989) was denied in a resolution dated February 22, 1990.
- Ancestry and personal background of Jose Ong, Jr.
- Grandfather Ong Te arrived from China in 1895, settled in Laoang, Samar, obtained a Spanish-era residence certificate; father Ong Chuan naturalized in 1957; mother Agripina Lao is a natural-born Filipina; Ong, Jr. was born in Laoang in 1948.
- Ong, Jr. grew up in Samar, pursued higher education and work in Manila but maintained ties with Laoang (built family homes, voted there in 1984 and 1986, registered in 1987).
- Constitutional context and SC petitions
- Petitioners invoked Article IV (citizenship) and Article VI (qualifications) of the 1987 Constitution.
- They filed petitions for certiorari in the Supreme Court, challenging the HRET’s finding as a grave abuse of discretion.
Issues:
- Whether the Supreme Court has jurisdiction to review final HRET decisions.
- Whether the HRET gravely abused its discretion in declaring Jose Ong, Jr. a natural-born Filipino citizen.
- Whether the HRET gravely abused its discretion in finding that Jose Ong, Jr. was a resident of the second district of Northern Samar for at least one year preceding the 1987 election.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)