Case Digest (G.R. No. 180088) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Manuel B. Japzon v. Commission on Elections and Jaime S. Ty, G.R. No. 180088, decided en banc on January 19, 2009 under the 1987 Constitution, petitioner Japzon and private respondent Ty both ran for Mayor of General Macarthur, Eastern Samar, in the May 14, 2007 local elections. On June 15, 2007, Japzon filed SPA No. 07-568 before the COMELEC First Division, seeking Ty’s disqualification and cancellation of his Certificate of Candidacy (COC) for material misrepresentation. Japzon alleged that Ty, a natural-born Filipino who had become a U.S. citizen and lived in America for 25 years, falsely stated in his March 28, 2007 COC that he had been a resident of Barangay 6, Poblacion, General Macarthur for one year prior to election day and that he was not a permanent resident or immigrant of any foreign country. Ty admitted naturalization in the U.S. but maintained that under Republic Act No. 9225 he had reacquired Philippine citizenship by taking his Oath of Allegiance on October 2 Case Digest (G.R. No. 180088) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- Manuel B. Japzon (Japzon) and Jaime S. Ty (Ty) were candidates for Mayor of General Macarthur, Eastern Samar, in the May 14, 2007 local elections.
- Ty was born a natural-born Filipino on October 9, 1943, later migrated to the U.S., became a naturalized American citizen, and resided there for 25 years.
- Petition for Disqualification
- On June 15, 2007, Japzon filed SPA No. 07-568 before the COMELEC First Division to disqualify Ty and cancel his Certificate of Candidacy (COC) for material misrepresentation.
- Japzon alleged Ty falsely claimed in his COC to have been a one-year resident of Barangay 6, Poblacion, General Macarthur, and not a foreign permanent resident, contrary to Section 39, RA 7160.
- Ty’s Answer and Supporting Acts
- Ty admitted U.S. naturalization but asserted he reacquired Philippine citizenship under RA 9225 by filing an application, taking an Oath of Allegiance on October 2, 2005, and later renouncing U.S. citizenship on March 19, 2007.
- Ty presented evidence of Philippine passport application (October 26, 2005), Community Tax Certificates (March 8, 2006; January 4, 2007), and voter registration in Barangay 6 (July 17, 2006).
- COMELEC Resolutions
- The COMELEC First Division (July 31, 2007) denied Japzon’s petition, finding Ty had validly reacquired Philippine citizenship and established domicile in General Macarthur by May 4, 2006.
- The COMELEC en banc (September 28, 2007) denied Japzon’s motion for reconsideration, affirming that Ty made no material misrepresentation and met all candidacy qualifications.
- Petition for Certiorari to the Supreme Court
- Japzon filed a Petition for Certiorari under Rules 64 and 65, alleging the COMELEC acted with grave abuse of discretion in adjudicating Ty’s domicile and residency.
- The Office of the Solicitor General and Ty opposed, invoking the binding nature of COMELEC’s factual findings and arguing that, even if Ty were disqualified, Japzon could not assume office as second placer.
Issues:
- Citizenship Reacquisition
- Whether Ty validly reacquired Philippine citizenship and renounced U.S. citizenship under RA 9225 before filing his COC.
- Residency Requirement
- Whether Ty met the one-year residency (domicile) requirement in General Macarthur, Eastern Samar, under Section 39, RA 7160, prior to the May 14, 2007 elections.
- COMELEC Discretion
- Whether the COMELEC committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying Japzon’s petition.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)