Case Digest (G.R. No. 207900) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Mayor Gamal S. Hayudini v. Commission on Elections and Mustapha J. Omar, G.R. No. 207900, decided on April 22, 2014 by the Supreme Court En Banc under the 1987 Constitution, petitioner Gamal S. Hayudini filed his Certificate of Candidacy (CoC) for Mayor of South Ubian, Tawi-Tawi on October 5, 2012. On October 15, 2012, Mustapha J. Omar lodged SPA No. 13-106(DC)(F) seeking to cancel Hayudini’s CoC for false representation of residence, alleging the latter was domiciled in Zamboanga City, not South Ubian. Thereafter, Hayudini secured inclusion in Barangay Bintawlan’s permanent voters’ list via MCTC on January 31, 2013; in turn, the COMELEC First Division that same day dismissed Omar’s petition for lack of proof. On March 8, 2013, RTC Branch 5 reversed the MCTC, ordered deletion of Hayudini’s name from the voters’ list, and this decision became final and executory. Omar filed a second petition (SPA No. 13-249(DC)(F)) on March 26, 2013 to cancel Hayudini’s CoC by reason of the su Case Digest (G.R. No. 207900) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and initial filings
- Gamal S. Hayudini filed his Certificate of Candidacy (CoC) on October 5, 2012 for Mayor of South Ubian, Tawi-Tawi.
- Mustapha J. Omar filed on October 15, 2012 a petition (SPA No. 13-106(DC)(F)) to deny due course or cancel Hayudini’s CoC, alleging false representation of residency.
- Voter registration proceedings and first CoC petition
- Hayudini sought inclusion in Barangay Bintawlan’s voters’ list; on January 31, 2013 the Municipal Circuit Trial Court (MCTC) granted his petition despite opposition.
- On the same day, the COMELEC First Division dismissed Omar’s first petition for lack of substantial evidence.
- RTC decision, CA appeal, elections, and second CoC petition
- On March 8, 2013, the RTC reversed the MCTC, deleting Hayudini’s name from the voters’ list; the decision became final and executory.
- Hayudini’s appeal to the Court of Appeals was denied on April 17, 2013.
- Hayudini won the mayoralty race on May 13, 2013, was proclaimed and took his oath.
- On March 26, 2013, Omar filed his second petition (SPA No. 13-249(DC)(F)) to cancel Hayudini’s CoC based on the RTC decision.
- COMELEC resolutions and this certiorari petition
- On June 20, 2013, the COMELEC Second Division granted Omar’s second petition, canceled Hayudini’s CoC, and directed a Special Board of Canvassers to proclaim the lawful winner.
- On July 10, 2013, the COMELEC En Banc denied Hayudini’s motion for reconsideration and proclaimed Salma A. Omar as duly elected mayor.
- Hayudini then filed a petition for certiorari and prohibition under Rule 65 challenging the assailed COMELEC resolutions.
Issues:
- Did the COMELEC commit grave abuse of discretion by admitting and granting Omar’s belated petition despite non-compliance with Rule 23, Sections 2 and 4?
- Did the COMELEC exceed its jurisdiction by revisiting its First Division’s final resolution in SPA No. 13-106(DC)(F)?
- Was the cancellation of Hayudini’s CoC and nullification of his proclamation lawful?
- Was the proclamation of Salma A. Omar as mayor proper under the law?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)