Case Digest (G.R. No. 137004) Core Legal Reasoning
Core Legal Reasoning
Facts:
The case involves Arnold V. Guerrero as the petitioner and Guillermo C. Ruiz, Rodolfo C. Fariñas, and the Commission on Elections (COMELEC) as the respondents. On May 10, 1998, the COMELEC Second Division dismissed Ruiz's petition to disqualify Fariñas from running for Congress in the first district of Ilocos Norte for the May 11, 1998 elections, based on allegations that Fariñas had campaigned without filing a Certificate of Candidacy. Ruiz claimed that Fariñas's actions violated Section 73 of the Omnibus Election Code and requested the COMELEC to recognize Fariñas as a "nuisance candidate" under Section 69. On May 8, 1998, Fariñas filed his Certificate of Candidacy, substituting for Chevylle V. Fariñas, who withdrew from the race on April 3, 1998. The COMELEC found Ruiz's petition without merit, asserting that without a filed certificate, there was no candidate to disqualify. Following the elections on May 11, 1998, Fariñas emerged as the winner with 56,
... Case Digest (G.R. No. 137004) Expanded Legal Reasoning
Expanded Legal Reasoning
Facts:
- Parties, filings and nature of the case
- Petitioner: Arnold V. Guerrero — filed a Petition‑in‑Intervention in COMELEC Case No. SPA 98‑227 and later brought the present special civil action (certiorari, prohibition, mandamus) before the Supreme Court challenging COMELEC actions.
- Respondents: Commission on Elections (COMELEC), Hon. Manuel B. Villar, Jr. (Speaker of the House), Hon. Roberto P. Nazareno (Secretary General, House of Representatives), Rodolfo C. FariAas (winning proclaimed candidate and Member of the House), and Guillermo C. Ruiz (original petitioner before COMELEC seeking disqualification of FariAas).
- Factual and procedural chronology
- Pre‑election petition: Guillermo C. Ruiz filed a verified petition in COMELEC Case No. SPA 98‑227 seeking to perpetually disqualify Rodolfo C. FariAas as a congressional candidate for Ilocos Norte, 1st District. Ruiz alleged FariAas campaigned without having filed a Certificate of Candidacy (COC) within the statutory filing period, thereby violating Section 73 of the Omnibus Election Code, and sought declaration of FariAas as a “nuisance candidate” under Section 69 and cancellation of any purported COC.
- Substitution and late filing: On May 8, 1998 Rodolfo C. FariAas filed a COC as a substitute for Chevylle V. FariAas, who had purportedly withdrawn on April 3, 1998. Ruiz filed an urgent ex parte motion on May 9 attaching the COC.
- COMELEC Second Division action: On May 10, 1998 the COMELEC Second Division dismissed Ruiz’s petition, stating there was no official candidacy in the records to cancel because there was no (previously filed) COC to be cancelled and thus “no candidate to be disqualified.”
- Election, proclamation and assumption of office: Elections proceeded on May 11, 1998; FariAas received the highest votes (56,369) for the 1st District and was proclaimed winner. FariAas took his oath and assumed office on June 3, 1998.
- Post‑election motions and intervention: Ruiz filed a motion for reconsideration (contending the substitution was invalid because Chevylle V. FariAas was allegedly an independent, and substitution by another person is allowed only where the original was an official candidate of a registered/accredited party). Guerrero filed a Petition‑in‑Intervention on June 10, 1998 asserting he was the official Liberal Party candidate and sought disqualification of FariAas and declaration of vacancy with special elections called (excluding FariAas).
- COMELEC En Banc disposition: The COMELEC En Banc denied relief and dismissed the motions and Guerrero’s intervention for lack of jurisdiction (declining to rule further on the validity of the COC), effectively deferring to the House Electoral Tribunal (HRET) once FariAas had been proclaimed and assumed office. The En Banc’s dispositive language advised that a quo warranto action could be filed if desired.
- Petition to the Supreme Court: Guerrero filed the present petition contending COMELEC gravely abused its discretion by (a) refusing to decide the validity of FariAas’s candidacy/COC; (b) improperly deferring/throwing jurisdiction to the HRET (which, petitioner contended, lacked jurisdiction over statutory qualification issues); and (c) failing to call a special election despite alleged vacancy caused by an unlawful candidacy.
Issues:
- Primary legal question
- Whether the COMELEC committed grave abuse of discretion in declining to determine the validity of Rodolfo C. FariAas’s certificate of candidacy and candidacy on the ground that, after proclamation and assumption of office, the exclusive jurisdiction to resolve contests concerning election, returns and qualifications of members of the House of Representatives lies with the House Electoral Tribunal (HRET).
- Subsidiary or related questions addressed by the Court
- Whether the term “qualifications” in Article VI, Section 17 of the Constitution (establishing the Electoral Tribunals) should be read as limited to constitutional qualifications under Article VI, Section 6, thereby excluding statutory qualifications (such as filing of a COC under the Omnibus Election Code) from HRET jurisdiction.
- Whether a proclamation that is alleged to be void ab initio (because of failure to comply with statutory prerequisites) prevents COMELEC from declining to act and requires COMELEC to continue to exercise jurisdiction despite the proclaimed person having assumed office.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)