G.R. No. 192571 - Abbott Laboratories, Philippines vs. Alcaraz

Teodulo M. Coquilla was born on February 17, 1938 in Oras, Eastern Samar, Philippines, and was originally a Filipino citizen.
In 1965 he enlisted in the United States Navy and became a naturalized U.S. citizen; he visited the Philippines briefly in 1970–1973 but otherwise resided in the U.S. until retirement in 1985 and thereafter.

On October 15, 1998, Coquilla returned to the Philippines, secured a residence certificate in Oras, and continued making trips to the U.S., the last from July 6 to August 5, 2000.
He applied for repatriation under R.A. No. 8171, was approved on November 7, 2000, took his Philippine citizenship oath on November 10, 2000, and received a Certificate of Repatriation and an Immigration ID Certificate in mid-November 2000.
He registered as a voter in Butnga, Oras on November 21, 2000; this registration was approved on January 12, 2001.

Coquilla filed his Certificate of Candidacy for mayor of Oras on February 27, 2001, representing that he had been a resident for two years; on March 5, 2001, incumbent mayor Alvarez petitioned to cancel it for material misrepresentation of residency.
The COMELEC Second Division did not decide before the May 14, 2001 elections; Coquilla received the highest vote count (6,131) and was proclaimed mayor on May 17, 2001.
On July 19, 2001, the COMELEC Second Division canceled his certificate for failing the one-year residency requirement; his motion for reconsideration was denied en banc on January 30, 2002, prompting this certiorari petition.

Whether Coquilla’s motion for reconsideration before the COMELEC en banc was non-pro forma and thus suspended the 30-day period to file a petition for certiorari.
Whether the COMELEC retained jurisdiction to cancel the certificate of candidacy after Coquilla’s proclamation as mayor.
Whether Coquilla met the one-year residency requirement in Oras immediately preceding the May 14, 2001 elections.
Whether Coquilla was denied due process by the COMELEC’s summary disposition without a formal hearing.
Whether Coquilla’s misrepresentation of residency in his certificate of candidacy warranted its cancellation.