G.R. No. L-16190 - Mayor vs. Villacete

Petitioners were long-time registered voters in the municipality of San Agustin, province of Romblon, having exercised their suffrage from 1934 up to and including the elections of 1957.
The petitioners were registered in various precincts as follows:

Lucio L. Mayor in Precinct No. 1.
Juan Moreno Yap, Felix Mayor Yap, Aurelia Moreno, and Clarita Ang Mayor in Precinct No. 3-A.
Esperanza Mayor in Precinct No. 2.
Adoracion Yap in Precinct No. 7.

Pablo Burguete initiated several petitions before the Justice of the Peace Court of San Agustin seeking to exclude the petitioners from the permanent list of voters on the ground that they were not Filipino citizens and therefore unqualified to vote.
Pending the hearing of these petitions, Burguete requested the elevation of these cases to the court of first instance because of the significance of the issues involved, a motion which was granted by the justice of the peace court.

The trial court lacked jurisdiction to consider petitions based on the citizenship of the petitioners, as such an inquiry was not within the purview of Section 121 in relation to Section 123 of the Revised Election Code.
The core issue involving their status as Filipino citizens could not be properly addressed in an exclusion case.

Despite these objections, the trial court denied the motion to dismiss.
Petitioners then signaled their intention to elevate the issue to the Supreme Court by filing a special civil action for prohibition with a request for a preliminary injunction and postponed hearing of the exclusion petitions.
Due to urgent circumstances and lack of time, the trial court pressed on with the hearing despite the pending special civil action.

One petitioner, Lucio L. Mayor, was an official candidate for mayor with a duly registered certificate of candidacy.
As a result, Mayor filed a petition for prohibition before the Supreme Court on November 6, 1959 (G.R. No. L-16190), seeking relief in light of the pending issue regarding his exclusion.
The petition for prohibition was given due course with a resolution dated November 9, 1959.
Despite this, the trial court proceeded on November 7, 1959, to hear all the exclusion cases including that affecting Mayor, subsequently ruling that the petitioners were not Filipino citizens and thus disqualified from voting.

Elections were held on November 10, 1959.
On December 11, 1959, the petitioners filed the present petition for certiorari.
The petitioners alleged that the trial court committed grave abuse of discretion amounting to lack of jurisdiction by proceeding with the exclusion cases.
The petitions were consolidated due to their interrelated issues.

Whether the trial court had jurisdiction to entertain exclusion petitions based on the citizenship status of the petitioners, given that such a question might fall outside the ambit of Section 121 in relation to Section 123 of the Revised Election Code.
Whether the issue on the qualification of voters (based on citizenship) in an exclusion case is appropriate for judicial inquiry at the level of the trial court.

Whether the pending special civil action for prohibition and the consequential petition for certiorari have served any useful purpose after the elections were held on November 10, 1959.
Whether the ruling of the trial court—disqualifying the petitioners on the ground of non-Filipino citizenship—remains operable and actionable once the elections have been concluded.

The inquiry into whether the summary character of a decision in an exclusion case renders it final and unappealable, and if such a decision may subsequently be reviewed or challenged by other legal remedies.