Case Digest (G.R. No. 135150) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 370 Phil. 625, petitioner Romeo Lonzanida seeks certiorari under Rule 65 to annul the COMELEC First Division resolution of May 21, 1998 and the COMELEC En Banc resolution of August 11, 1998 in SPA 98-190, which disqualified him from running for mayor of San Antonio, Zambales, in the May 1998 elections on the ground that he had already served three consecutive terms. Lonzanida had been duly elected and served two full terms as mayor prior to the May 1995 elections. In that election he was proclaimed winner and assumed office, but his proclamation was unsuccessfully contested by Juan Alvez before the Regional Trial Court of Zambales, which on January 9, 1997 declared a failure of elections. On November 13, 1997, the COMELEC resolved the protest in favor of Alvez, finding he received a plurality of valid votes; a writ of execution issued on February 27, 1998 unseated Lonzanida, and Alvez served the remainder of the term. Undeterred, Lonzanida filed his certificate of candidacy f Case Digest (G.R. No. 135150) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Romeo Lonzanida’s Prior Service
- Served two consecutive terms as Municipal Mayor of San Antonio, Zambales (before May 1995).
- Ran in the May 8, 1995 elections; was proclaimed winner and assumed office.
- Election Protest by Juan Alvez
- Juan Alvez filed protest before RTC Zambales; January 9, 1997 decision declared a failure of elections and vacancy of the mayoralty.
- COMELEC (Nov. 13, 1997) resolved protest in favor of Alvez (1,720 vs. 1,488 votes); Lonzanida was ordered out by writ of execution (Feb. 27, 1998) and Alvez assumed office.
- 1998 Mayoral Elections and Disqualification Petition
- Lonzanida filed Certificate of Candidacy for May 11, 1998 elections; Eufemio Muli filed petition to disqualify him (April 21, 1998) alleging he had already served three consecutive terms.
- Lonzanida was proclaimed winner (May 13, 1998); COMELEC First Division (May 21) and En Banc (Aug. 11, 1998) resolutions held him disqualified and struck out all votes cast for him.
- Contentions in Supreme Court
- Petitioner Lonzanida:
- Only duly elected for two terms; 1995–1998 tenure should not count because he was later unseated.
- COMELEC lost jurisdiction after his proclamation; proper remedy is quo warranto before RTC.
- Respondent Muli:
- Petition timely filed before elections; COMELEC retains jurisdiction under RA 6646 §6 and COMELEC Rule 25.
- Lonzanida discharged mayoral duties for nearly three years (1995–1998), thus service counts as one full term.
- Solicitor-General (COMELEC):
- Term-limit bars more than three consecutive “service of a term,” and service is measured by discharge of duties.
- COMELEC proper forum for disqualification petitions filed before elections.
Issues:
- Does Lonzanida’s assumption of office (May 1995–March 1998) count as service of one full term for purposes of the three-term limit under the Constitution and LGC?
- Did the COMELEC retain jurisdiction to resolve the disqualification petition after Lonzanida’s proclamation in the 1998 elections?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)