Case Digest (G.R. No. 56968)
Facts:
- Rodolfo de Leon is the petitioner; Commission on Elections (COMELEC) and Conrado Lindo are the respondents.
- The case arose from the municipal elections on January 30, 1980, in Ternate, Cavite.
- De Leon, a KBL candidate, was proclaimed the duly-elected mayor.
- Lindo, also from KBL but running as an independent, faced a disqualification petition from de Leon on January 25, 1980.
- The disqualification was based on Lindo's alleged failure to meet the six-month residency requirement, claiming he was a resident of Noveleta, Cavite.
- De Leon submitted a supplemental letter on January 28, 1980, including a certification from the barangay captain asserting Lindo's residency since 1969.
- Despite the pending petition, elections proceeded, and de Leon was proclaimed mayor.
- On February 28, 1980, COMELEC denied de Leon's petition, citing insufficient evidence against Lindo.
- De Leon's motion for reconsideration was also denied, with COMELEC stating the issue was moot since de Leon had assumed office.
Issue:
- (Unlock)
Ruling:
- The Supreme Court upheld COMELEC's decision, affirming the dismissal of the disqualification petition.
- The Court found no violation of procedural due process in the proceedings before COMELEC.
- The Court concluded that the ...(Unlock)
Ratio:
- The Supreme Court reasoned that the dismissal of the disqualification petition aligned with established legal principles regarding pre-proclamation controversies.
- De Leon's pursuit of disqualification after his election and assumption of office was deemed unwarranted, as he had other remedies available, such as a protest or quo warranto.
- The Court noted that de Leon failed to provide sufficient evidence to support his claims against Lindo, and the certifications submitted were inadequate to prove Lindo's alleged lack of residency.
- De Leon did not request a formal hearing to pre...continue reading
Case Digest (G.R. No. 56968)
Facts:
The case involves Rodolfo de Leon as the petitioner and the Commission on Elections (COMELEC) along with Conrado Lindo as the respondents. The events leading to this case unfolded during the municipal elections held on January 30, 1980, in Ternate, Cavite. Rodolfo de Leon was the KBL candidate who was eventually proclaimed the duly-elected mayor after the elections. Conrado Lindo, also from the KBL but running as an independent candidate, was the subject of a disqualification petition filed by de Leon on January 25, 1980. The basis for the disqualification was Lindo's alleged failure to meet the six-month residency requirement, with claims that he was a resident of Noveleta, Cavite prior to filing his certificate of candidacy.
In support of his petition, de Leon submitted a supplemental letter on January 28, 1980, which included a certification from Amado Melo, the barangay captain of San Rafael II, Noveleta, asserting that Lindo had been a resident of that barangay since 1969. Despite the pending disqualification petition, the elections proceeded on January 30, 1980, and de Leon was proclaimed mayor shortly thereafter. On February 28, 1980, COMELEC denied de Leon's petition, stating that he failed to provide sufficient evidence against Lindo. De Leon's subsequent motion for reconsideration was also denied, with COMELEC noting that the controversy had become moot since de Leon had already assumed office and was performing his duties as mayor. The Commission highlighted that Lindo had voted ...