G.R. No. 228248 - People vs. De Guzman y De Castro

Marino P. Morales (Morales) was elected Mayor of the Municipality of Mabalacat, Pampanga from 1 July 2007 to 30 June 2010 and re-elected in 2010.
On 15 May 2012, Republic Act No. 10164 converted the Municipality of Mabalacat into a Component City (Mabalacat City). A plebiscite ensued to ratify this conversion.
In the 2013 elections, Morales was elected Mayor of the newly created Mabalacat City.

Morales filed his Certificate of Candidacy (COC) on 8 December 2015 for the May 2016 elections as substitute candidate for Wilfredo Feliciano.
On 4 January 2016, Pyra Lucas (Lucas), a rival candidate, filed a Petition for Cancellation of Morales’ COC and/or Disqualification before COMELEC, alleging Morales was disqualified due to exceeding the three consecutive term limit. Lucas argued that conversion of the municipality to a city did not interrupt Morales’ terms served.
Morales filed a Verified Answer on 25 January 2016, contending the petition be dismissed for lack of certification against forum shopping, untimeliness, lack of jurisdiction, and absence of cause of action. Morales argued his term was interrupted by conversion, hence he was eligible to run.

After canvassing election returns, Morales was proclaimed elected Mayor, and Christian C. Halili (Halili) proclaimed elected Vice Mayor on 10 May 2016.
Crisostomo Garbo (Garbo), a mayoralty candidate who obtained second highest votes, filed a Motion to Intervene on 20 May 2016, seeking to be proclaimed Mayor if Morales’ COC was cancelled.
Halili filed a Verified Motion to Intervene (as Respondent) on 28 June 2016, asserting his right to be proclaimed Mayor in case of vacancy pursuant to Section 44 of RA 7160 (Local Government Code).
Morales opposed both interventions as premature on 16 December 2016.

On 3 August 2016, COMELEC First Division granted Lucas’ petition, cancelled Morales’ COC, declared votes cast for Morales as stray, and ordered proclamation of the next highest candidate, Garbo. It held Lucas’ petition timely and Morales’ COC contained false material representation as he was ineligible due to violating the three-term rule.
On 26 May 2017, the COMELEC En Banc denied Morales’ motion for reconsideration and affirmed the First Division’s resolution. Garbo was declared the qualified Mayor.
COMELEC En Banc issued a Writ of Execution on 8 June 2017 ordering Morales to cease performing as Mayor and directed proclamation of Garbo as duly elected Mayor.

Halili filed a Petition for Certiorari (G.R. No. 231643) challenging COMELEC’s decision on several grounds including the non-application of succession rules.
Morales filed a similar Petition for Certiorari (G.R. No. 231657), raising procedural and substantive arguments attacking the COMELEC resolutions and their handling of the petition to cancel his COC.
The Supreme Court consolidated the cases and denied motions for Temporary Restraining Orders filed by both petitioners.

Whether the COMELEC gravely abused its discretion in applying the precedent in Aratea v. COMELEC to declare Garbo, the second placer, as the qualified mayoral candidate with the highest votes.
Whether the COMELEC committed grave abuse of discretion by failing to declare the office of Mayor of Mabalacat City permanently vacant pursuant to Section 44 of RA 7160 after cancelling Morales’ COC.
Whether COMELEC gravely abused its discretion in ordering the City Board of Canvassers to proclaim the next highest candidate instead of following succession rules.

Whether the COMELEC gravely abused discretion in treating Lucas’ petition as a Petition to Deny Due Course despite lacking a clear allegation of deliberate material misrepresentation.
Whether the petition should have been dismissed outright for being defective, filed out of time, and lacking certification against forum shopping as required by COMELEC rules.
Whether a prior authoritative ruling on Morales’ eligibility was necessary before cancelling his COC in light of Poe v. COMELEC.
Whether the COMELEC lost jurisdiction to cancel Morales’ COC after his proclamation and assumption of office, making the matter moot and proper remedy quo warranto.
Whether the COMELEC gravely abused jurisdiction in proclaiming Garbo as qualified candidate and replacing Morales.