A.M. No. 326-CJ - Villa vs. Llamas

Petitioner Benjamin T. Loong filed his certificate of candidacy for the position of Vice-Governor of the Mindanao Autonomous Region on 15 January 1990, which was the last permissible day.
Two private respondents, Nur Hussein Ututalum and Alim Bashir Edris, also filed their candidacies for the same office.
The election for the regional officials was held on 17 February 1990.

On 5 March 1990, 49 days after Loong’s certificate was filed and 16 days after the election, respondent Ututalum filed a petition (docketed as SPA No. 90-006) before the Commission on Elections (COMELEC) Second Division, seeking to disqualify Loong on the ground that he falsely represented his age in his certificate of candidacy.
On 7 March 1990, respondent Edris intervened by filing a Petition in Intervention, raising issues similar to those in Ututalum’s petition.

On 19 March 1990, Loong filed his Answer to the petition in SPA No. 90-006, moving for its dismissal and asserting:

That the traditional practice in his community did not involve recording births with the Civil Registry, hence his true age was authenticated by his mother and community members.
That COMELEC lacked jurisdiction on the ground that the petition was not filed within the 25-day period mandated by Section 78 of the Omnibus Election Code.

On 15 May 1990, the COMELEC Second Division rendered a resolution holding that it had jurisdiction to hear and decide SPA No. 90-006, relying on the interpretation of the Frivaldo case and various legislative enactments, including Sections 6 and 7 of Republic Act No. 6646.
The resolution justified that petitions alleging false representation in a certificate of candidacy related to a candidate’s eligibility are seasonable if filed within a reasonable time after the discovery of the ineligibility, regardless of any procedural filing deadlines.
On 3 July 1990, after denying Loong’s motion for reconsideration of the earlier resolution, COMELEC issued another resolution and proclaimed petitioner Loong as the duly elected Vice-Governor of the Mindanao Autonomous Region.

On 9 July 1990, petitioner Loong filed a special civil action of certiorari challenging the COMELEC resolutions dated 15 May 1990 and 3 July 1990.
The core factual dispute centered on whether SPA No. 90-006, the disqualification petition, was filed within the period prescribed by law.

Whether SPA No. 90-006 was filed within the 25-day period prescribed by Section 78 of the Omnibus Election Code, which governs petitions to cancel a certificate of candidacy based on false representation.
Whether the alleged misrepresentation regarding the candidate's age can justify an exception to the prescribed filing period.

Whether COMELEC’s reliance on Section 3, Rule 25 of its Rules of Procedure and Sections 6 and 7 of Republic Act No. 6646 to consider the petition as timely is proper, given the clear statutory deadline.
Whether a constitutional body like COMELEC possesses the jurisdiction to extend or modify the filing period set by legislative enactment as a matter of procedure.