Case Digest (G.R. No. 241742) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Ramon L. Labo, Jr. v. Commission on Elections (G.R. No. 105111) and the cross‐petition Roberto C. Ortega v. Commission on Elections (G.R. No. 105384), both decided on July 3, 1992, the Supreme Court addressed the pre‐election disqualification of Ramon Labo, Jr. for the mayoralty race in Baguio City. Believing himself a natural‐born Filipino, Labo filed his certificate of candidacy on March 23, 1992. Two days later, his rival Roberto Ortega filed a disqualification petition with the Comelec (SPA No. 92-029), alleging that Labo falsely declared his citizenship. Despite summons on March 27 and personal service on April 24, Labo failed to timely answer, prompting Ortega’s motion to declare him in default. At the May 4 hearing, Ortega presented the Court’s 1989 ruling in Labo v. Commission on Elections (176 SCRA 1) declaring Labo not a citizen; Labo offered no evidence and filed his answer only on May 5. On May 9, the Comelec resolved to cancel Labo’s certificate of candidacy. Aft Case Digest (G.R. No. 241742) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Parties
- Ramon L. Labo, Jr. (Labo) filed his certificate of candidacy for Mayor of Baguio City on March 23, 1992, declaring himself a “natural-born” Filipino citizen.
- Roberto C. Ortega (Ortega) filed his certificate for the same position on March 25, 1992, and on March 26, 1992, lodged a disqualification petition (SPA No. 92-029) before the Comelec alleging Labo’s false claim of Filipino citizenship.
- Proceedings Before the Comelec
- Summons and Default
- Summons issued March 27, 1992; Labo failed to answer within the non-extendible three-day period.
- Ortega moved to declare Labo in default on April 15, 1992; Comelec ordered personal service of summons on April 24, 1992.
- Hearing and Evidence
- On May 4, 1992, Ortega presented the 1989 Supreme Court decision (176 SCRA 1) declaring Labo not a Filipino citizen.
- Labo did not present evidence and filed his Answer only on May 5, 1992, reiterating his Filipino citizenship claim and citing the U.S. case Vance v. Terrazas.
- Comelec Resolutions
- May 9, 1992 – Comelec resolved to cancel Labo’s certificate of candidacy for false material representation.
- May 10, 1992 – Clarification that the May 9 resolution would become final and executory after five days, allowing Labo to remain on the ballot pending Supreme Court action.
- May 13, 1992 – Comelec motu proprio suspended Labo’s proclamation if he won.
- Supreme Court Petitions
- GR No. 105111 (Labo’s Petition)
- Filed May 15, 1992 seeking: (i) temporary restraining order on Comelec’s May 9 resolution; (ii) declaration of his Filipino citizenship; and (iii) direction to proclaim him if elected.
- GR No. 105384 (Ortega’s Petition)
- Filed June 1, 1992 as mandamus to compel Comelec to implement the May 9 resolution and declare Ortega Mayor-elect based on second-highest votes.
- Submission for Decision
- On June 16, 1992, the Supreme Court resolved to consider both petitions submitted for decision.
Issues:
- GR No. 105111 (Labo’s Petition)
- Whether the Comelec gravely abused its discretion in canceling Labo’s certificate of candidacy and declaring him not a Filipino citizen despite his claims of reacquisition of citizenship.
- Whether Labo’s alleged ongoing application for repatriation and reliance on Sec. 72 of the Omnibus Election Code (now repealed) and Vance v. Terrazas can validate his candidacy or stay implementation of the disqualification.
- GR No. 105384 (Ortega’s Petition)
- Whether the May 9, 1992 Comelec resolution disqualifying Labo became final and executory, obliging its immediate execution.
- Whether Ortega, as the candidate with the next highest number of votes, is entitled to proclamation as Mayor-elect upon Labo’s disqualification.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)