G.R. No. L-52431 - Farinas vs. Commission on Elections

On January 4, 1980, Rodolfo C. Farinas, 28, filed his certificate of candidacy with the election registrar of Laoag City as the standard bearer of the Nacionalista Party for mayor in the January 30, 1980 election.
Later that same day, at 4:30 p.m., Farinas filed another certificate of candidacy with the Commission on Elections (Comelec) in Manila, indicating his nomination by the Kilusang Bagong Lipunan (KBL) as its official candidate for mayor.
Concurrently, Farinas sent a letter to the Laoag City election registrar formally withdrawing his first certificate under the Nacionalista banner, asserting that his initial filing was a mistake and that he was indeed running as a KBL candidate.
On January 8, 1980, Ernesto T. Farinas wrote to the provincial election registrar confirming that Rodolfo C. Farinas was heading the KBL ticket for Laoag City elective positions.
On January 20, 1980, Laoag City was officially declared a “free zone” for the KBL, signifying its recognition as part of the party’s domain.

On January 20, 1980, Antonio F. Lazo, the other KBL candidate for mayor, filed a petition with the Comelec seeking to disqualify Farinas based on the existence of the two conflicting certificates of candidacy.
Farinas was duly served with a copy of the petition and he answered it on January 25, 1980; however, his answer was initially unverified.
A hearing was promptly conducted on the following day (January 26, 1980) at 4:00 p.m. in a summary proceeding, where no oral evidence was received and only the exhibits attached to the pleadings were considered.

On January 28, 1980, the Comelec, through Resolution No. 8547 in PDC No. 158, decided to disqualify Farinas by holding that:

His situation amounted to turncoatism.
He had engaged in partisan political activities before the designated campaign period, citing Presidential Decrees Nos. 1296 and 1661 as the legal basis.

On January 29, 1980, Farinas filed a petition for certiorari in the Supreme Court to assail the Comelec resolution.
A restraining order was immediately issued by the Court, effectively keeping Farinas on the KBL ballot.
Despite the pending disqualification, Farinas won the election with a 6,419-vote margin over Lazo and was proclaimed mayor on February 6, 1980 after the Comelec lifted the suspension of the proclamation.
On February 13, 1980, Farinas moved to withdraw his petition on the grounds that it had become moot due to his proclamation, though respondent Lazo contested this characterization by noting previous allegations that the case would be rendered moot by the proclamation.

The abbreviated, summary hearing of the disqualification petition raised concerns about the adequacy of due process.
There was an implication that Farinas was denied a full opportunity to present his case, given the rushed proceedings and the opportunity for evidence submission.

Whether the Comelec’s abbreviated hearing on the disqualification petition provided Farinas with adequate due process.

Examination of the procedural fairness in handling conflicting certificates of candidacy.
Determination of whether the evidentiary phase was sufficiently completed before rendering the disqualification resolution.

Whether the issue of turncoatism and premature partisan activity, as applied by the Comelec under Presidential Decrees Nos. 1296 and 1661, should invalidate Farinas’ candidacy.
Impact of Farinas’ subsequent election and proclamation as mayor on the pending disqualification proceedings.

Consideration of competing motions: Farinas’ motion to withdraw his petition versus Lazo’s contention that the case remains live and relevant.