Facts:

The case involves Mauyag B. Papandayan, Jr. as the petitioner and the Commission on Elections (COMELEC) along with Fahida P. Balt as the respondents. The events unfolded during the May 14, 2001 elections for the position of Municipal Mayor of Tubaran, Lanao del Sur. Respondent Balt contested the candidacy of petitioner Papandayan, alleging that he was not a resident of Tubaran. On May 8, 2001, the COMELEC issued a resolution disqualifying Papandayan from running for mayor, ordering that his name be removed from the list of candidates and that any votes cast in his favor be considered stray. Papandayan's motion for reconsideration was denied on May 12, 2001. Despite this disqualification, he received the highest number of votes in the election. On May 17, 2001, he filed a petition for certiorari with the Supreme Court, seeking to annul the COMELEC's resolutions. He also filed a petition with the COMELEC on May 19, 2001, requesting that the Board of Election Inspectors ...

Facts:

Election and Disqualification Proceedings

• Petitioner Mauyag B. Papandayan, Jr. and respondent Fahida P. Balt were candidates for the position of Municipal Mayor of Tubaran, Lanao del Sur in the May 14, 2001 elections.
• Respondent Balt filed a disqualification case against petitioner before the Commission on Elections (COMELEC), alleging that petitioner was not a resident of Tubaran.
• On May 8, 2001, the COMELEC declared petitioner disqualified and ordered his name to be stricken off the list of candidates, with votes cast in his favor considered stray.
• Petitioner's motion for reconsideration was denied by the COMELEC on May 12, 2001.

Election Results and Subsequent Actions

• Despite the disqualification, petitioner received the highest number of votes in the May 14, 2001 elections.
• On May 17, 2001, petitioner filed a petition for Certiorari with the Supreme Court, seeking to annul the COMELEC's disqualification resolutions.
• On May 19, 2001, petitioner filed a petition (SPC No. 01-039) with the COMELEC, requesting the Board of Election Inspectors (BEI) to count and tally his votes, citing COMELEC Resolution No. 4116.
• Respondent Balt filed a pre-proclamation case (SPC No. 01-259) seeking the exclusion of election returns.

Temporary Restraining Order (TRO) and Proclamation

• On May 22, 2001, the Supreme Court issued a TRO, enjoining the COMELEC from implementing its disqualification resolutions.
• On May 29, 2001, the COMELEC granted petitioner's petition to count and tally his votes but ordered the suspension of his proclamation pending the resolution of the disqualification case.
• Despite the suspension order, the Municipal Board of Canvassers proclaimed petitioner as mayor on June 3, 2001.
• Respondent Balt filed a motion to annul the proclamation, which the COMELEC granted on June 25, 2001, citing violations of its May 29, 2001 order and the pendency of the pre-proclamation case.

Supreme Court Decision and Final Resolution

• On April 16, 2002, the Supreme Court reversed the COMELEC's disqualification resolutions, declaring petitioner eligible to run for mayor.
• The Supreme Court ruled that the annulment of petitioner's proclamation was a necessary consequence of its decision in the disqualification case.
• The Court upheld the COMELEC's June 25, 2001 order annulling the proclamation but noted that the pre-proclamation case had been terminated by COMELEC Resolution No. 4493, removing any impediment to petitioner's proclamation.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Effect of Disqualification Case Resolution: The Supreme Court's decision in the disqualification case, which reversed the COMELEC's disqualification of petitioner, rendered the COMELEC's orders suspending and annulling his proclamation ineffective.
2. Proclamation and Pre-Proclamation Cases: The Court upheld the COMELEC's authority to annul the proclamation under Section 20(i) of Republic Act No. 7166, which prohibits the proclamation of a candidate unless authorized by the COMELEC after ruling on objections. However, the termination of the pre-proclamation case removed any legal impediment to petitioner's proclamation.
3. Jurisdiction of COMELEC: The COMELEC acted within its jurisdiction in suspending and annulling the proclamation, but its orders were superseded by the Supreme Court's decision in the disqualification case.