Case Digest (G.R. No. 227158)
Facts:
- Joseph C. Dimapilis (petitioner) filed his Certificate of Candidacy (CoC) for re-election as Punong Barangay of Barangay Pulung Maragul, Angeles City, on October 11, 2013.
- He declared under oath his eligibility for the position.
- Dimapilis was proclaimed the winner on October 29, 2013.
- On the same day, the Commission on Elections (COMELEC) Law Department filed a Petition for Disqualification against him.
- The petition cited Section 40(b) of Republic Act No. 7160 (Local Government Code of 1991), claiming Dimapilis was disqualified due to a prior administrative conviction for Grave Misconduct.
- This conviction resulted in his dismissal from service and a perpetual disqualification from holding public office, as determined by the Office of the Ombudsman (OMB) on June 23, 2009.
- The COMELEC Second Division ordered Dimapilis to respond to the petition on December 17, 2013.
- Dimapilis argued for dismissal of the petition on various grounds, including improper combination of disqualification and cancellation of CoC and an injunction from the Regional Trial Court (RTC) of Angeles City.
- On April 11, 2016, the COMELEC Second Division ruled in favor of the petition, canceling Dimapilis's CoC and annulling his proclamation.
- His motion for reconsideration was denied by the COMELEC En Banc on August 31, 2016, prompting him to file a petition for certiorari with the Supreme Court.
Issue:
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Ruling:
- The Supreme Court dismissed the petition, upholding the COMELEC's resolutions dated April 11, 2016, and August 31, 2016, which canceled Dimapilis's CoC and...(Unlock)
Ratio:
- The Court determined that Dimapilis's perpetual disqualification from holding public office was a significant fact affecting his eligibility, rendering his CoC void from the beginning.
- According to Section 74 of the Omnibus Election Code (OEC), a CoC must affirm the candidate's eligibility, and any misrepresentation regarding this eligibility is grounds for cancellation.
- The Court highlighted that the COMELEC has a constitutional obligation to enforce election laws, i...continue reading
Case Digest (G.R. No. 227158)
Facts:
The case involves Joseph C. Dimapilis (petitioner) and the Commission on Elections (COMELEC) as the respondent. The events leading to this case began when Dimapilis, who had previously served as the Punong Barangay of Barangay Pulung Maragul in Angeles City, filed his Certificate of Candidacy (CoC) for re-election on October 11, 2013, for the upcoming Barangay Elections scheduled for October 28, 2013. In his CoC, he declared under oath that he was eligible for the position. Following the elections, he was proclaimed the winner on October 29, 2013. However, on the same day, the COMELEC Law Department filed a Petition for Disqualification against him, citing Section 40(b) of Republic Act No. 7160, the Local Government Code of 1991 (LGC). The petition claimed that Dimapilis was disqualified from running due to a prior administrative conviction for Grave Misconduct, which resulted in his dismissal from service and the accessory penalty of perpetual disqualification from holding public office, as determined by the Office of the Ombudsman (OMB) in a decision dated June 23, 2009.
The COMELEC Second Division issued an order on December 17, 2013, directing Dimapilis to respond to the petition. In his response, he argued that the petition should be dismissed on several grounds, including the improper combination of disqualificatio...