Facts:

The case involves Meliton C. Geronimo as the petitioner against several respondents, including Lt. Gen. Fidel V. Ramos, the Commission on Elections (COMELEC), and others. The controversy arose from the mayoralty elections in Baras, Rizal, held on January 30, 1980. Geronimo was initially disqualified from running for mayor due to allegations of political turncoatism, as filed by private respondent Julian Pendre with the COMELEC on January 8, 1980. The COMELEC issued Resolution No. 8305 on January 19, 1980, disqualifying Geronimo. Despite this, he won the election with 2,695 votes against his opponent Bayani Ferrera, who received 2,370 votes.

On March 11, 1980, the COMELEC reinstated Geronimo's proclamation as the winning candidate, but this was made temporary pending the Supreme Court's decision on Geronimo's petition for certiorari. On September 26, 1981, the Supreme Court dismissed Geronimo's petition, affirming his disqualification. Following this, the CO...

Facts:

Election Disqualification

• On January 8, 1980, Julian Pendre filed a petition with the Commission on Elections (COMELEC) to disqualify Meliton C. Geronimo from running as a candidate for mayor of Baras, Rizal, on the grounds of political turncoatism.
• On January 19, 1980, COMELEC issued Resolution No. 8305, disqualifying Geronimo.
• Geronimo filed a motion for reconsideration on January 22, 1980, and on January 28, 1980, he filed a petition for certiorari with the Supreme Court to restrain COMELEC from implementing the resolution. The Court issued a temporary restraining order on the same day.

Election Results

• In the January 30, 1980 elections, Geronimo won with 2,695 votes against Bayani Ferrera's 2,370 votes.
• On March 11, 1980, COMELEC issued Resolution No. 9554, reinstating Geronimo's proclamation as mayor, but it was declared temporary pending the Supreme Court's decision.

Supreme Court Decision

• On September 26, 1981, the Supreme Court dismissed Geronimo's petition for certiorari in G.R. No. 52413, affirming his disqualification for political turncoatism. Geronimo's motion for reconsideration was denied on January 19, 1982.

COMELEC Resolution No. 82-428

• On February 15, 1982, COMELEC issued Resolution No. 82-428, which:
  1. Declared Geronimo's certificate of candidacy null and void.
  2. Declared all votes cast for Geronimo as "stray" votes.
  3. Proclaimed Bayani Ferrera as the duly elected mayor.
  4. Directed Geronimo to turn over the mayoralty office to Ferrera.

Occupation of Municipal Hall

• On May 3, 1982, Geronimo and his followers occupied the Municipal Hall of Baras, paralyzing official business. Ferrera held office in his house during this period.
• On May 4, 1982, Pendre filed a motion to cite Geronimo for contempt.
• On May 12, 1982, COMELEC issued Resolution No. 82-605, finding Geronimo guilty of contempt and sentencing him to five months imprisonment and a fine of P1,000.

Forcible Removal and Arrest

• On May 14, 1982, Geronimo and his followers were forcibly removed from the Municipal Hall by the military using teargas and gunshots. Geronimo was arrested and detained at the National Penitentiary.

Criminal Charges

• Between April and May 1982, criminal charges were filed against Geronimo and his followers, including usurpation of authority, sedition, and illegal possession of firearms.

Petitions Filed

• On May 29, 1982, Geronimo filed a petition for habeas corpus (G.R. No. 60504), challenging his detention.
• On May 31, 1982, Geronimo filed another petition (G.R. No. 60591) to annul COMELEC Resolution No. 82-605.
• On June 16, 1982, Geronimo and 75 others filed a petition (G.R. Nos. 60732-39) seeking the dismissal of criminal charges against them.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Contempt Proceedings: The Court held that COMELEC did not commit grave abuse of discretion in finding Geronimo guilty of contempt. However, the penalty of five months imprisonment was deemed excessive. The Court emphasized that contempt powers should be exercised on the preservative and corrective principles, not for vindictive purposes.
2. Election Disqualification and Succession: The Court ruled that the disqualification of a winning candidate does not entitle the second-placed candidate to assume office. Instead, a permanent vacancy is created, and the vice-mayor should succeed to the position. This upholds the principle that the electorate's choice must be respected, and a repudiated candidate cannot be imposed on the voters.
3. Criminal Charges and Preliminary Investigation: The Court found that the hasty issuance of warrants of arrest and the filing of multiple criminal charges against Geronimo and his followers were improper. The Court emphasized the importance of due process in preliminary investigations and the need for judges to carefully determine probable cause before issuing warrants.

Concurring Opinion (Teehankee, Acting C.J.)

• Justice Teehankee concurred, emphasizing that the disqualification of a winning candidate does not transfer the victory to the losing candidate. He stressed that the vice-mayor should assume the office in case of a permanent vacancy, as this respects the electorate's will and prevents the disenfranchisement of voters.

Conclusion:

The Court upheld the principles of due process, the sanctity of the electorate's choice, and the proper exercise of judicial and prosecutorial discretion. It ruled against the imposition of a repudiated candidate as mayor and emphasized the importance of fair and thorough preliminary investigations in criminal cases.