Case Digest (G.R. No. 148862) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In March 1995, Juan G. Frivaldo filed his Certificate of Candidacy for Governor of Sorsogon. Three days later, his opponent, Raul R. Lee, petitioned the Commission on Elections (COMELEC) to cancel it on the ground that Frivaldo was not a Philippine citizen. On May 1, 1995, COMELEC’s Second Division disqualified Frivaldo and cancelled his candidacy; the en banc affirmed on May 11, though Frivaldo’s name remained on the ballot. In the May 8 election, Frivaldo secured the highest votes, but the Provincial Board of Canvassers later proclaimed Lee governor on June 30, acting on a June 21 COMELEC order. Believing himself to have reacquired Philippine citizenship under Presidential Decree No. 725 after taking his oath of allegiance on June 30 at 2 p.m., Frivaldo petitioned COMELEC (SPC No. 95-317) on July 6 to annul Lee’s proclamation and proclaim him governor. On December 19, 1995, COMELEC’s First Division granted Frivaldo’s petition and ordered his proclamation; the en banc denied Le Case Digest (G.R. No. 148862) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Cases
- G.R. No. 120295 – Juan G. Frivaldo’s petition to annul Comelec Resolutions of May 1 and May 11, 1995 disqualifying him for lack of Philippine citizenship.
- G.R. No. 123755 – Raul R. Lee’s petition for certiorari and preliminary injunction to annul Comelec First Division Resolution (Dec. 19, 1995) and en banc Resolution (Feb. 23, 1996) ordering Frivaldo’s proclamation.
- Disqualification Proceedings
- March 23, 1995 – Lee files SPA No. 95-028 to disqualify Frivaldo, alleging alien status.
- May 1, 1995 – Comelec Second Division disqualifies Frivaldo; May 11, 1995 – Comelec en banc affirms.
- Election, Canvass, and Proclamations
- May 8, 1995 – Frivaldo obtains highest votes (73,440); Lee is second (53,304).
- June 29–30, 1995 – Comelec en banc proclaims Lee; Frivaldo takes oath of allegiance under P.D. 725 at 2:00 p.m. and files SPC No. 95-317 to annul Lee’s proclamation.
- Repatriation under P.D. 725
- August 17, 1994 – Frivaldo files application for repatriation; Special Committee reactivated June 8, 1995.
- June 30, 1995 – Committee approves repatriation; Frivaldo takes oath at Malacañang.
- Consolidation and Supreme Court Proceedings
- March 12, 1996 – Supreme Court consolidates G.R. Nos. 120295 and 123755.
- March 19, 1996 – Oral arguments; parties file memoranda.
Issues:
- Was Frivaldo’s repatriation valid, did it cure his lack of citizenship, and may its effect be given retroactive operation?
- Is a judicially declared lack of citizenship a continuing disqualification to run for and hold elective local office?
- Did Comelec have jurisdiction over SPC No. 95-317, filed post-proclamation to annul Lee’s proclamation?
- Was Lee’s proclamation valid under prevailing jurisprudence (e.g., the Labo doctrine)?
- Did Comelec exceed its jurisdiction by deciding Lee’s disqualification petition after the 15-day cut-off in Section 78 of the Omnibus Election Code?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)