Case Digest (G.R. No. 137004)
Facts:
Arnold v. Guerrero, G.R. No. 137004, July 26, 2000, the Supreme Court En Banc, Quisumbing, J., writing for the Court. Petitioner Arnold V. Guerrero filed a Rule 65 petition for certiorari, prohibition, and mandamus (with a prayer for TRO/preliminary injunction) challenging the Commission on Elections' rulings dismissing efforts to disqualify Rodolfo C. Farinas as candidate for Congressman, First District, Ilocos Norte.Respondent Guillermo R. Ruiz originally filed a petition in the COMELEC Second Division (COMELEC Case No. SPA 98-227) to disqualify Farinas, alleging Farinas campaigned without having filed a certificate of candidacy in violation of Sec. 73, Omnibus Election Code, and seeking declaration that Farinas was a "nuisance candidate" under Sec. 69, Omnibus Election Code. On May 8, 1998 Farinas filed a certificate of candidacy as a substitute for Chevylle V. Farinas (who had withdrawn April 3, 1998). Ruiz filed an urgent ex parte motion on May 9 attaching Farinas's certificate.
On May 10, 1998 the COMELEC Second Division dismissed Ruiz's petition for utter lack of merit, stating there was no certificate of candidacy in the records to cancel and consequently no candidate to be disqualified. The May 11, 1998 elections proceeded and Farinas received 56,369 votes and was proclaimed the winner. Ruiz moved for reconsideration on May 16, 1998, arguing substitution was improper because Chevylle was an independent and not an official party candidate.
Farinas took his oath on June 3, 1998. On June 10, 1998 Guerrero filed a petition-in-intervention in the COMELEC case claiming he was the Liberal Party's official candidate and asking that the congressional seat be declared vacant and special elections called, disallowing Farinas. On January 6, 1999 the COMELEC En Banc affirmed the Second Division and dismissed the motion for reconsideration and Guerrero's petition-in-intervention for lack of jurisdiction, without prejudice to filing quo warranto. Guerrero then elevated the matter to the Supreme Court ...(Subscriber-Only)
Issues:
- Did the COMELEC commit grave abuse of discretion by refusing to rule on the validity of Farinas's certificate of candidacy and by deferring the matter to the HRET?
- Is the HRET's jurisdiction under Article VI, Section 17 of the Constitution limited only to the constitutional qualifications in Article VI, Section 6, excluding statutory requirements such as filing a certificate of candidacy under the Omnibus Election Code?
- Does the COMELEC retain jurisdiction to declare a proclamation void ab initio for failure to meet statutory candidacy requirements after the procl...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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