Title
Ibrahim vs. Commission on Elections
Case
G.R. No. 192289
Decision Date
Jan 8, 2013
The Supreme Court annuls the COMELEC's disqualification of Ibrahim as Vice-Mayor, ruling it exceeded its jurisdiction and that the MBOC's role is solely to canvass votes.
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Case Digest (G.R. No. 192289)

Facts:

  • Kamarudin K. Ibrahim (Petitioner) filed his certificate of candidacy for Vice-Mayor of Datu Unsay, Maguindanao, on December 1, 2009, for the May 10, 2010 elections.
  • Rolan G. Buagas, the Acting Election Officer, reported to the Commission on Elections (COMELEC) that Ibrahim and other candidates were not registered voters in the municipality.
  • The COMELEC's Law Department recommended disqualification, leading to Minute Resolution No. 09-0946 on December 22, 2009, disqualifying Ibrahim for lack of voter registration.
  • Ibrahim, along with 50 other candidates, filed a Petition/Opposition against the disqualification, citing previous instances of candidates participating without disqualification.
  • The COMELEC denied their opposition on May 6, 2010, confirming Ibrahim's disqualification based on official certifications.
  • Despite receiving the highest votes, the Municipal Board of Canvassers (MBOC) suspended Ibrahim's proclamation due to the COMELEC's resolutions.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court granted Ibrahim's petition, annulling the COMELEC's resolutions dated December 22, 2009, and May 6, 2010.
  • The suspension of Ibrahim's proclamation by the MBOC was also annull...(Unlock)

Ratio:

  • The Court found that the COMELEC en banc exceeded its jurisdiction by disqualifying Ibrahim without a proper petition or complaint.
  • The authority to cancel a certificate of candidacy lies with the COMELEC sitting in division, not en banc, as per Section 3(C), Article IX of the 1987 Constitution.
  • The resolutions issued by the COMELEC en banc were null and void due to lack of autho...continue reading

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