G.R. No. 159831 - Pilipinas Shell Petroleum Corp. vs. John Bordman Ltd. of Iloilo Inc.

The case arose from the May 11, 1992 synchronized elections in which Eugenio Jurilla, Marciano Medalla, Bernardo Nazal, Rey Medina, Melencio Castelo, Godofredo Liban, and Antonio V. Hernandez were candidates for one of the six available councilor positions of the Second District of Quezon City.
Dispute centered on the certificate of candidacy filed by Antonio V. Hernandez and the apparent deficiencies therein.

On March 23, 1992, Antonio V. Hernandez submitted his certificate of candidacy to the Commission on Elections (COMELEC).
In Item No. 6 of his certificate, he provided his address as “B 26, L 1 New Capitol Estates, Quezon City.”
However, in the space meant for indicating the Precinct Number and the specific Barangay of registration (Item No. 12), he left the details blank.
His submitted biodata indicated a different address, “Acacia Street, Mariana, Quezon City,” which fell within the Fourth District, thereby creating a discrepancy in his electoral affiliation.
The contention arose because Sec. 39, paragraph (a) of the Local Government Code of 1991 requires a candidate to be a registered voter in the district where he is running, but it does not explicitly mandate the certificate of candidacy to contain the precise precinct number and Barangay of registration.

In response to the discrepancy, private respondent Hernandez explained that at the time he filed his certificate he had not yet been assigned a particular Precinct Number in the Second District of Quezon City.
It was further revealed that although he was formerly a registered voter in Manila, he had been a resident of “B 26, L 1 New Capitol Estates” in Quezon City for the two years prior to the election.
Hernandez subsequently filed a Petition for Inclusion in the Registry of Registered Voters of Second District, Quezon City, explaining his late registration due to illness (Acute Gastroenteritis) and his intention to vote at Precinct 233-B.
Testimonies, including that of Barangay Captain Manuel Laxina, confirmed that Hernandez was indeed a resident of New Capitol Estates for at least two years prior to the elections.

Petitioners challenged Hernandez’s qualification before COMELEC after discovering the alleged deficiency post-election, filing their petition under Rule 25 of the COMELEC Rules of Procedure (which permits filing after the deadline but before the proclamation date).
On June 2, 1992, COMELEC issued a resolution denying the petition on the grounds that it was filed outside the reglementary period specified in Section 5 of RA 6646, relating to nuisance candidates.
The petitioners also attempted to categorize Hernandez as a “nuisance candidate” under Sec. 69 of BP Blg. 881, asserting that his certificate was intended to create confusion among the voters.
Despite the petitioners’ allegations, subsequent judicial confirmation established Hernandez as a duly registered voter of Precinct No. 233-B, thereby affirming his qualifications to run for the office contested.

Whether the petition challenging Hernandez’s qualification, filed under Rule 25 of the COMELEC Rules of Procedure, was timely given the reglementary period provided by law.
Determination of whether the petitioners should have instead invoked provisions relating to nuisance candidates at the appropriate stage of the election process.

Whether the failure by Hernandez to indicate his Precinct Number and specific Barangay in the certificate of candidacy constituted a fatal defect given that the law (Sec. 39, para (a) of the Local Government Code of 1991) does not explicitly require these particulars.
The relevance and impact of the discrepancy between the address shown in his certificate of candidacy and that in his biodata on his qualification as a candidate.

Whether categorizing Hernandez as a “nuisance candidate” was proper under Sec. 69 of BP Blg. 881 based on the facts presented.
Whether the procedural mechanism provided under Sec. 69 could be properly invoked in the context of Hernandez’s candidacy.