Title
Guro vs. Commission on Elections
Case
G.R. No. 234345
Decision Date
Jun 22, 2021
A mayoral candidate's disqualification petition was dismissed as filed beyond the 25-day reglementary period, upheld by the Supreme Court for strict rule application without exceptional circumstances.
A

Case Digest (G.R. No. 234345)

Facts:

Saripoden Ariman Guro v. Commission on Elections and Somerado Malomalo Guro, G.R. No. 234345, June 22, 2021, the Supreme Court En Banc, Rosario, J., writing for the Court.

Petitioner Saripoden Ariman Guro, the incumbent mayor of Lumbaca-Unayan running for reelection, filed a Petition for Disqualification on April 29, 2016 against private respondent Somerado Malomalo Guro, who had filed his Certificate of Candidacy (COC) for Municipal Mayor on October 16, 2015. Petitioner alleged that private respondent was not a registered voter of the municipality as shown in the posted certified voters’ list and therefore was ineligible to be a candidate.

Private respondent answered on June 13, 2016, denying the material allegations and asserting that the COMELEC had approved a recommendation to include his name in the supplemental list of voters, that he was able to vote on Election Day, and that he was proclaimed mayor after the May 2016 elections. The COMELEC First Division dismissed petitioner’s disqualification petition by Order dated October 19, 2016 on the ground that it was filed beyond the 25-day prescriptive period for petitions under Section 78 of the Omnibus Election Code (OEC). The COMELEC En Banc affirmed by Resolution dated September 25, 2017, likewise concluding the petition was time-barred and declining to reach the merits.

Petitioner elevated the matter to the Supreme Court via a petition for certiorari under Rule 64 in relation to Rule 65 of the Rules of Court, alleging gr...(Subscriber-Only)

Issues:

  • Did the COMELEC commit grave abuse of discretion amounting to lack or excess of jurisdiction by dismissing petitioner’s disqualification petition as filed beyond the reglementary period?
  • Should the COMELEC have relaxed its reglementary period and resolved the petition on the merits given the allegation that private respondent misrepresen...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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