G.R. No. L-60504 - IN RE: Geronimo vs. Ramos

The interrelated petitions arose from the mayoralty elections in Baras, Rizal in 1980.
Meliton C. Geronimo, elected as mayor, was subsequently disqualified for political turncoatism by COMELEC.
The disqualification was based on Section 10, Article XII-C of the pre-amended Constitution, Presidential Decree No. 1661, and Batas Pambansa No. 52.

On January 8, 1980, Julian Pendre filed a petition with the COMELEC to disqualify Geronimo.
The COMELEC issued Resolution No. 8305 on January 19, 1980, disqualifying Geronimo for political turncoatism.
Geronimo sought relief by filing a motion to reconsider the resolution on January 22, 1980.
On January 28, 1980, two days before the elections, Geronimo filed a petition for certiorari with the Court to restrain the COMELEC’s resolution, leading to a temporary restraining order.

On January 30, 1980, Geronimo won the mayoralty with 2,695 votes over opponent Bayani Ferrera’s 2,370 votes, with a margin of 325 votes.
On March 11, 1980, COMELEC issued Resolution No. 9554, reinstating Geronimo’s proclamation as mayor on a temporary basis, pending the Court’s decision.
On September 26, 1981, the Court dismissed Geronimo’s petition for certiorari in G.R. No. 52413 and lifted the restraining order, thus affirming his disqualification.

On February 15, 1982, COMELEC issued Resolution No. 82-428 which set aside Geronimo’s temporary proclamation and declared:

Geronimo filed various motions for reconsideration and an urgent motion to set aside COMELEC resolutions, but these motions were either denied or merely noted without substantive relief.

On May 3–13, 1982, Geronimo, together with more than fifty followers, occupied the Baras Municipal Hall, disrupting official business.
On May 14, 1982, following confrontation with military forces and the Philippine Constabulary, Geronimo was forcibly removed from the municipal hall, with gunshots and teargas used.
Geronimo was eventually seized, handcuffed, and detained at the National Penitentiary in Muntinglupa.
A series of criminal charges were later filed against Geronimo and around 75 others for offenses including usurpation of authority, tumultuous affray, sedition, illegal possession of firearms, disobedience, and alarm and scandal.

Geronimo filed a habeas corpus petition (G.R. No. 60504) alleging illegal arrest and detention, asserting that COMELEC’s resolution finding him in contempt was issued with grave abuse of discretion.
A second petition (G.R. No. 60591) sought to annul COMELEC Resolution No. 82-605 which declared him in contempt and dismissed his motions.
A third petition (G.R. Nos. 60732-39) was filed by Geronimo and 75 others, seeking the dismissal of the criminal complaints and challenging the hasty issuance of arrest warrants.
The petitioner contended that:

There was no legal basis for his detention as the due process requirements were met.
COMELEC’s actions were marred by grave abuse of discretion.
The proclamation of Bayani Ferrera, who did not secure the plurality of votes, as mayor was an error.

Whether Geronimo’s actions in defying the COMELEC’s affirmed decision constitute sufficient grounds for a contempt finding.
Whether proper due process was observed in notifying and giving Geronimo an opportunity to be heard in the contempt proceeding.

Whether the COMELEC exceeded its power by proclaiming Bayani Ferrera, who did not procure the plurality of votes, as the duly elected mayor.
Whether declaring Geronimo’s votes as “stray” is justified given that the votes were cast in good faith for a candidate presumed qualified.

Whether the issuance of arrest warrants and the subsequent criminal charges against Geronimo and his followers were the product of a proper preliminary investigation.
Whether the haste and manner in which the criminal proceedings were conducted infringe upon the due process rights of those charged.