Case Digest (G.R. No. 192760)
Facts:
In Mercado v. Manzano, petitioner Ernesto S. Mercado and private respondent Eduardo B. Manzano competed for Vice Mayor of Makati City in the May 11, 1998 elections. Manzano, who was born in San Francisco to Filipino parents on September 14, 1955, registered with the Philippine Bureau of Immigration as an alien (ACR No. B-31632) yet never renounced his Filipino citizenship. After Manzano garnered 103,853 votes against Mercado’s 100,894, a third candidate, Gabriel V. Daza III, trailed with 54,275 votes. Prior to proclamation, Ernesto Mamaril filed a petition with the COMELEC Second Division alleging Manzano’s dual citizenship under Section 40(d) of the Local Government Code (R.A. No. 7160), which disqualifies dual citizens from elective local office. On May 7, 1998, the Second Division cancelled Manzano’s certificate of candidacy. Manzano moved for reconsideration, which remained pending through the election, prompting the Board of Canvassers to suspend his proclamation. Mercado sCase Digest (G.R. No. 192760)
Facts:
- Election and initial vote count
- In the May 11, 1998 Makati vice-mayoral race, candidates were Eduardo B. Manzano (103,853 votes), Ernesto S. Mercado (100,894 votes), and Gabriel V. Daza III (54,275 votes).
- Mercado trailed Manzano by 2,959 votes; Manzano’s proclamation was suspended due to a disqualification petition.
- COMELEC disqualification proceedings
- Ernesto Mamaril filed a petition before the COMELEC Second Division, alleging Manzano’s dual citizenship under Section 40(d) of the Local Government Code.
- On May 7, 1998, the Second Division canceled Manzano’s certificate of candidacy; Manzano’s motion for reconsideration remained pending through the election.
- COMELEC en banc resolution and certiorari petition
- On August 31, 1998, the COMELEC en banc (4–1, 1 abstention) reversed the Second Division, ruled Manzano qualified, and directed his proclamation.
- Mercado filed a petition for certiorari in the Supreme Court to annul the en banc resolution and declare Manzano disqualified.
Issues:
- Whether Mercado had legal personality (locus standi) to file certiorari despite not being an original party in the disqualification proceedings.
- Whether Manzano’s dual citizenship constituted “dual allegiance” disqualifying him under Section 40(d), Local Government Code.
- Whether Manzano effectively renounced U.S. citizenship—by voting in Philippine elections and via his Certificate of Candidacy oath—thus terminating his dual-citizenship status.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)