G.R. No. 115324 - Producers Bank of the Philippines vs. Court of Appeals

Petitioner Mariz Lindsey Tan Gana-Carait (Gana-Carait) filed on 17 October 2018 her Certificate of Candidacy (CoC) as Member of the Sangguniang Panlungsod of Biñan City, Laguna, for the 13 May 2019 National and Local Elections.
On 22 October 2018, respondent Rommel Mitra Lim filed a petition to disqualify Gana-Carait, alleging she acquired U.S. citizenship and did not renounce it before seeking office.
On 6 November 2018, respondent Dominic P. NuAez filed a petition to deny due course to or cancel her CoC for alleged material misrepresentation that she was eligible to run despite holding U.S. citizenship.
Gana-Carait answered and moved to consolidate both petitions.

On 27 February 2019, the COMELEC First Division resolved to dismiss the disqualification petition but granted cancellation of Gana-Carait’s CoC, finding her a dual citizen by naturalization who failed to comply with RA 9225’s renunciation and oath requirements.
Gana-Carait filed a Motion for Partial Reconsideration on 5 March 2019.
On 23 September 2021, the COMELEC En Banc denied her motion for lack of merit and affirmed the First Division.

Petitioner filed on 12 October 2021 a Petition for Certiorari and Prohibition under Rule 64 in relation to Rule 65 of the Rules of Court, assailing the COMELEC En Banc Resolution as a grave abuse of discretion.
The COMELEC issued a Certificate of Finality and Writ of Execution (Dec 2021–Jan 2022), but the Supreme Court found the En Banc resolution not yet final due to the timely petition.
The Court consolidated issues of finality, scope of RA 9225, dual citizenship by birth versus naturalization, and material misrepresentation.

Whether the COMELEC En Banc Resolution became final and executory before the timely Rule 64 petition.
How to harmonize COMELEC procedural rules with the Constitution and Rules of Court on the 30-day period to seek certiorari.

Whether RA 9225’s oath of allegiance and renunciation requirements apply to natural-born Filipinos who acquired foreign citizenship by birth.
Distinction between dual citizenship by birth and by naturalization under Philippine and U.S. law.

Whether Gana-Carait made a false representation in her CoC that she was eligible to run for office.
Whether her dual citizenship status, without renunciation or separate oath, rendered her ineligible.