Case Digest (G.R. No. 221538) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Rizalito Y. David v. Senate Electoral Tribunal and Mary Grace Poe-Llamanzares (G.R. No. 221538, September 20, 2016), petitioner Rizalito Y. David challenged the qualifications of private respondent Senator Mary Grace Poe-Llamanzares before the Senate Electoral Tribunal (SET) by filing a petition for quo warranto on August 6, 2015. David alleged that Poe was not a natural-born citizen of the Philippines under Article IV, Section 1 and Article VI, Section 3 of the 1987 Constitution because she was a foundling whose Filipino parentage could not be established. Poe was discovered as an infant outside the Parish Church of Jaro, Iloilo on September 3, 1968 and was thereafter registered as a foundling and later adopted by the Poe family. She acquired various public documents—including birth, adoption, voter, and passport records—always recognized as Filipino until her naturalization as a U.S. citizen in 2001. Under Republic Act No. 9225 she took an Oath of Allegiance in 2006 and app Case Digest (G.R. No. 221538) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the dispute
- Rizalito Y. David (petitioner) filed, on August 6, 2015, a quo warranto petition before the Senate Electoral Tribunal (SET) seeking to unseat Mary Grace Poe-Llamanzares (respondent) from her Senate seat for allegedly not being a natural-born Filipino citizen.
- Respondent was born a foundling, abandoned at the Parish Church of Jaro, Iloilo on September 3, 1968; her biological parents are unknown.
- Respondent’s early legal status and identification
- A Foundling Certificate was issued on September 6, 1968, and she was named Mary Grace Natividad Contreras Militar.
- On May 13, 1974, the Municipal Court of San Juan, Rizal, granted her adoption by Ronald Allan Poe (Fernando Poe Jr.) and Jesusa Sonora Poe, changing her name to Mary Grace Natividad Sonora Poe.
- She became a registered voter (1986) and obtained successive Philippine passports (1988, 1993, 1998, 2009, 2013, 2014).
- U.S. naturalization, reacquisition, and renunciation
- Naturalized as a U.S. citizen on October 18, 2001; obtained a U.S. passport thereafter.
- On July 7, 2006, took the Oath of Allegiance under Republic Act No. 9225; her petition for reacquisition of Philippine citizenship was granted on July 18, 2006.
- Executed an Affidavit of Renunciation of U.S. citizenship on October 20, 2010; Certificate of Loss of Nationality issued by U.S. authorities on December 9, 2011.
- Proceedings before the Senate Electoral Tribunal
- SET issued resolutions requiring correction of defects, submission of records (Bureau of Immigration, National Statistics Office) and respondent’s answer; held oral arguments on September 21, 2015.
- Respondent submitted DNA test results (November 5, 2015) showing no conclusive parental matches; SET treated case as submitted.
- On November 17, 2015, SET dismissed the quo warranto petition, ruling respondent a natural-born citizen; denied motion for reconsideration on December 3, 2015.
Issues:
- Jurisdictional issue
- Did the SET commit grave abuse of discretion, amounting to lack or excess of jurisdiction, in dismissing the quo warranto petition?
- Substantive issue
- Is Mary Grace Poe-Llamanzares a natural-born Filipino citizen qualified to hold the office of Senator under Article VI, Section 3 of the 1987 Constitution?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)