Title
Domino vs. Commission on Elections
Case
G.R. No. 134015
Decision Date
Jul 19, 1999
DOMINO disqualified for failing to meet one-year residency requirement for Sarangani Representative; SC upheld COMELEC's decision due to insufficient evidence.

Case Digest (G.R. No. 134015)
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)

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