Title
Jalosjos vs. Commission on Elections
Case
G.R. No. 191970
Decision Date
Apr 24, 2012
Rommel Jalosjos, reacquired Philippine citizenship, faced residency challenges for gubernatorial candidacy; SC ruled he met requirements, overturning COMELEC’s disqualification.
A

Case Digest (G.R. No. 191970)

Facts:

  • Early life and citizenship changes
    • Born October 26, 1973 in Quezon City; migrated to Australia in 1981 and acquired Australian citizenship.
    • Returned to the Philippines on November 22, 2008; lived with his brother in Barangay Veterans Village, Ipil; took oath of allegiance to the Republic of the Philippines; issued a Certificate of Reacquisition of Philippine Citizenship; renounced Australian citizenship on September 1, 2009 under R.A. 9225.
  • Property acquisitions and voter registration
    • Purchased a residential lot in Barangay Veterans Village and a fishpond in San Isidro, Naga, Zamboanga Sibugay.
    • Applied for voter registration in Ipil; opposed by Barangay Captain Dan Erasmo, Sr.; the Election Registration Board approved the application; the MCTC and, on appeal, the RTC denied Erasmo’s petition to exclude Jalosjos from the voters list.
  • Candidacy and COMELEC proceedings
    • Filed a Certificate of Candidacy for Governor of Zamboanga Sibugay on November 28, 2009; Erasmo filed a petition to deny due course or cancel the COC alleging material misrepresentation for non-compliance with R.A. 9225 and the one-year residency requirement.
    • The COMELEC Second Division and, on reconsideration, the COMELEC En Banc disqualified Jalosjos for failure to prove domicile in Ipil; the Supreme Court issued a status quo ante order; Jalosjos won the 2010 gubernatorial election and was proclaimed winner.

Issues:

  • Main issue
    • Whether the COMELEC gravely abused its discretion in ruling that petitioner Rommel Apolinario Jalosjos failed to present ample proof of a bona fide intention to establish his domicile in Ipil, Zamboanga Sibugay, and thus did not meet the one-year residency requirement to qualify as provincial governor.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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