G.R. No. 109618 - People vs. Bea, Jr.

On March 24, 1998, incumbent Mayor Jose “Pempe” Miranda filed his certificate of candidacy (COC) for a fourth consecutive term in Santiago City, Isabela.
On March 27, Antonio M. Abaya filed a petition to deny due course to and/or cancel that COC (SPA 98-019), alleging ineligibility under the three-term limit.
On May 5, 1998, the COMELEC First Division granted Abaya’s petition, ruling that Miranda’s COC was denied due course and/or cancelled and that he was disqualified from running.

On May 6, 1998, Joel G. Miranda (son of Jose “Pempe”) filed his COC as substitute candidate under Section 77, Omnibus Election Code.
Elections on May 11, 1998: Joel Miranda garnered 22,002 votes; Abaya received 20,336. Joel was proclaimed mayor.
On May 13, Abaya filed SPA 98-288 to nullify Joel’s substitution and enjoin his proclamation, arguing no valid original candidacy existed to be substituted.

On May 16, 1998, the COMELEC First Division dismissed SPA 98-288. Abaya moved for reconsideration.
On December 8, 1998, the COMELEC En Banc granted reconsideration: it annulled Joel’s election and proclamation, cancelled his certificate of canvass, and directed the city board to reconvene and proclaim Abaya.
On December 9, Joel petitioned this Court for certiorari with TRO; on December 11, the Court issued a TRO and required comments.

Whether the annulment of Joel G. Miranda’s substitution and proclamation was issued without jurisdiction or with grave abuse of discretion.
Whether directing the proclamation of Abaya as mayor constituted grave abuse of discretion or lack of jurisdiction.