Facts:

• Petitioner Mozart P. Panlaqui challenged the Commission on Elections (Comelec) En Banc Resolution dated June 17, 2009.
• The resolution denied Panlaqui's motion for proclamation as mayor of Sasmuan, Pampanga.
• The Supreme Court had previously nullified the proclamation of private respondent Nardo M. Velasco as mayor due to disqualification.
• Velasco, born to Filipino parents, became a U.S. citizen in 1983 and later applied for dual citizenship under Republic Act No. 9225, approved on July 31, 2006.
• Velasco took his oath of allegiance to the Philippines on the same date and returned to the Philippines on September 14, 2006.
• He applied for voter registration in Sasmuan on October 13, 2006, which was initially denied by the Election Registration Board (ERB).
• The Municipal Trial Court (MTC) of Sasmuan reversed the ERB's decision on February 9, 2007, but the Regional Trial Court (RTC) of Guagua, Pampanga, reversed the MTC's decision on March 1, 2007.
• The Court of Appeals dismissed Velasco's appeal on August 19, 2008.
• Despite these legal battles, Velasco filed his Certificate of Candidacy (COC) for mayor on March 28, 2007, claiming his status as a registered voter.
• Panlaqui filed a petition before the Comelec to deny due course to or cancel Velasco's COC based on gross material misrepresentation regarding his residency and voting qualifications.
• Velasco won the May 2007 elections and assumed office.
• The Comelec later found material misrepresentation on Velasco's part, canceled his COC, and nullified his proclamation through resolutions dated July 6, 2007, and October 15, 2007, which the Supreme Court affirmed.
• Panlaqui's subsequent motion for proclamation was denied by the Comelec, leading to the present petition.
• Panlaqui argued that the RTC's March 1, 2007 decision should be considered a final judgment of disqualification against Velasco before the elections, invoking the case of Cayat v. Commission on Elections as a precedent.

Issue:

• (Unlock)

Ruling:

• The Supreme Court dismissed the petition and affirmed the Comelec's June 17, 2009 Resolution, thereby denying Panl...(Unlock)

Ratio:

• The Supreme Court held that the Comelec did not commit grave abuse of discretion in denying Panlaqui's motion for proclamation.
• The Court clarified that the RTC's March 1, 2007 decision in the voter's inclusion proceedings did not equate to a final judgment of disqualification against Velasco before the elections.
• The Court distinguished between voters' inclusion/exclusion proceedings and COC denial/cancellation proceedings, noting that they involve different issues, reliefs, and remedies.
• The RTC's decision on Velasco's right to vote did not tra...continue reading