Case Digest (G.R. No. 229984) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the Philippine Supreme Court case G.R. No. 256053 decided on November 5, 2024, petitioner Vice Mayor Peter Bascon Miguel filed a Petition for Review on Certiorari challenging the jurisdiction of the Regional Trial Court (RTC) of Koronadal City over a quo warranto complaint he filed against respondent, then City Mayor Eliordo Usero Ogena. Both Miguel and Ogena were duly elected as Vice Mayor and Mayor of Koronadal City, South Cotabato, in the May 13, 2019 National and Local Elections, and they assumed office on June 30, 2019. Miguel filed a Complaint for Quo Warranto before the RTC on August 29, 2019, alleging that Ogena was disqualified from holding elective office due to penalties imposed on him by the Supreme Court in an earlier administrative case (AC No. 9807) decided on February 2, 2016, which found Ogena guilty of violating the 2004 Rules on Notarial Practice, suspending him from the practice of law for two years and permanently barring him from performing notarial serv Case Digest (G.R. No. 229984) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Election Background
- Petitioner Peter Bascon Miguel and Respondent Eliordo Usero Ogena were elected Vice Mayor and Mayor, respectively, of Koronadal City in the May 13, 2019 National and Local Elections.
- Both were proclaimed by the City Board of Canvassers on May 15, 2019 and assumed office on June 30, 2019.
- Quo Warranto Complaint
- On August 29, 2019, Miguel filed a Complaint for Quo Warranto before the RTC against Ogena, alleging disqualification to hold public office.
- The grounds for disqualification stemmed from penalties imposed on Ogena in the Supreme Court’s Decision dated February 2, 2016, in Administrative Case (AC) No. 9807.
- Administrative Case Against Ogena (AC No. 9807)
- Complaint filed with the Integrated Bar of the Philippines by deceased client's children, alleging falsification of documents.
- Supreme Court found no conclusive proof of forgery but ruled Ogena violated the 2004 Rules on Notarial Practice.
- Penalty imposed: Suspension from practicing law for two years and permanent barring from performing notarial acts.
- Opposition by Ogena
- Filed an answer arguing that the quo warranto should be filed with COMELEC within 10 days from proclamation as per Omnibus Election Code (OEC).
- Questioned Miguel’s legal standing, lack of jurisdiction, and cause of action.
- RTC Decisions
- March 5, 2020 Decision: Granted Miguel’s quo warranto complaint, found Ogena disqualified and unlawfully holding the mayoralty, ousted him, and declared position vacant.
- July 7, 2020 Resolution: Granted Ogena’s motion for reconsideration, set aside previous decision for lack of jurisdiction, dismissed case.
- Court of Appeals Decision
- December 15, 2020: Affirmed RTC July 7, 2020 Resolution. Held COMELEC has exclusive jurisdiction over quo warranto against elected city officials under OEC and Constitution.
- Supreme Court Petition
- Miguel sought review arguing RTC had jurisdiction under Rule 66 of Rules of Court.
- Contended penalties on Ogena amount to grounds for disqualification under Section 40(a) and (b) of Local Government Code (LGC).
Issues:
- Whether the Regional Trial Court has jurisdiction over the quo warranto action filed against an elected city official, Ogena.
- Whether the penalty of suspension from law practice and permanent barring from notarial service imposed on Ogena constitutes grounds for disqualification under Section 40(a) and (b) of the LGC.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)