Case Digest (G.R. No. 134015) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On 25 March 1998, Juan Domino filed his Certificate of Candidacy for Representative of the Lone Legislative District of Sarangani, claiming residency in the province since January 1997. On 30 March 1998, private respondents Narciso R. Grafilo, Jr., Eddy B. Java, Juan P. Bayonito, Jr., Rosario Samson, and Dionisio P. Lim, Sr., lodged SPA No. 98-022 with the COMELEC Second Division, alleging that Domino remained a registered voter and resident of Quezon City as of 22 June 1997. Their evidence included his Voter’s Registration Record, Community Tax Certificates, past Certificate of Candidacy for Quezon City (1995), and applications for transfer of registration. Domino countered with a January 1997 lease contract, a November 1997 deed of sale for his Alabel, Sarangani residence, the January 1998 Metropolitan Trial Court decision excluding him from the Quezon City voters’ list, transfer approvals by the Election Registration Board, affidavits of Sarangani residents, and tax returns. Case Digest (G.R. No. 134015) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- On 25 March 1998, Juan Domino filed his Certificate of Candidacy (COC) for Representative of the Lone Legislative District of Sarangani, declaring a one-year, two-month residence in the district.
- On 30 March 1998, private respondents filed Petition SPA No. 98-022 with the COMELEC Second Division to deny due course to or cancel Domino’s COC, alleging he was not a resident or registered voter of Sarangani.
- On 6 May 1998, the COMELEC Second Division issued a resolution disqualifying Domino for lack of the one-year residence requirement and canceling his COC.
- Elections were held on 11 May 1998; Domino received the highest votes, but COMELEC Supplemental Omnibus Resolution No. 3046 suspended any proclamation due to the pending disqualification case.
- On 29 May 1998, the COMELEC en banc denied Domino’s motion for reconsideration. Domino then petitioned the Supreme Court for certiorari with a prayer for preliminary injunction. A status quo order was issued on 14 July 1998.
- On 15 September 1998, Lucille Chiongbian-Solon, the second-placer, was allowed to intervene, seeking to uphold Domino’s disqualification and to be proclaimed in his stead.
- Evidence Presented
- Private respondents’ Exhibits
- Annex A–COC indicating residence and voter registration in Sarangani.
- Annex B–Voter’s Registration Record (VRR) dated 22 June 1997 showing registration in Quezon City.
- Annexes C–F–Community Tax Certificates and letters revealing multiple issuances and registrations outside Sarangani.
- Annex G–1995 COC showing birthdate and residence claims in Quezon City.
- Annex H–Application for transfer of registration dated 30 August 1997.
- Annex I–Sworn application for cancellation of previous registration dated 22 October 1997.
- Domino’s Defense Exhibits
- Annex 1–Lease contract for Sarangani property executed 15 January 1997.
- Annex 2–Deed of sale of the same property on 4 November 1997.
- Annex 3–MTC Decision of 19 January 1998 excluding Domino from Quezon City voter list and approving transfer to Sarangani.
- Annexes 4–7 –Applications and approvals for transfer of VRR to Sarangani in late 1997.
- Annexes 8–8-e –Affidavits and certifications of Sarangani residents attesting to Domino’s residency since January 1997.
- Annexes 9–9-b –Income Tax Returns for 1997.
- Annex 10 –Domino’s affidavit reciting chronology of his move to Sarangani.
Issues:
- Whether the Metropolitan Trial Court (MTC) decision in the voter exclusion proceedings is final, conclusive, and binding on the COMELEC.
- Whether Domino resided in Sarangani for at least one year immediately preceding the 11 May 1998 election.
- Whether the COMELEC has jurisdiction to cancel Domino’s COC after the election but before proclamation.
- Whether Intervenor Chiongbian-Solon, as the second-placer, may be proclaimed Representative after Domino’s disqualification.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)