Case Digest (G.R. No. 133944)
Facts:
- Marcita Mamba Perez filed a petition against Rodolfo E. Aguinaldo and the Commission on Elections (COMELEC).
- Aguinaldo submitted his certificate of candidacy for Representative of the Third District of Cagayan on March 26, 1998.
- Perez claimed Aguinaldo did not meet the one-year residency requirement before the May 11, 1998 elections, as per Article VI, Section 6 of the 1987 Philippine Constitution.
- She presented Aguinaldo's past candidacies and voter registration records showing his residence outside the Third District.
- Aguinaldo argued he had resided in Tuguegarao since July 1990, providing evidence to support his claim.
- The COMELEC dismissed Perez's petition on May 10, 1998, and Aguinaldo won the election.
- Perez's motion for reconsideration was denied, leading her to file a petition for certiorari.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the COMELEC did not commit grave abuse of discretion in dismissing the petition.
- The Court held that the COMELEC lost jurisdiction after Aguinaldo's proclamation. ...(Unlock)
Ratio:
- The Supreme Court emphasized that substantial evidence supported Aguinaldo's residency in Tuguegarao for over a year before the election.
- The residency requirement aims to ensure representatives understand their constituents' needs.
- Previous voter registration in Gattaran did not negate Aguinaldo's residency claim, as actual living ...continue reading
Case Digest (G.R. No. 133944)
Facts:
This case involves Marcita Mamba Perez as the petitioner and the Commission on Elections (COMELEC) and Rodolfo E. Aguinaldo as the respondents. The events leading to this case began when Aguinaldo filed his certificate of candidacy for the position of Representative of the Third District of Cagayan on March 26, 1998, for the upcoming elections scheduled for May 11, 1998. Four days later, on March 30, 1998, Perez, a voter and citizen, filed a petition with the COMELEC seeking to disqualify Aguinaldo from running for office. She argued that Aguinaldo had not resided in the Third District for at least one year prior to the election, as mandated by Article VI, Section 6 of the 1987 Philippine Constitution. To support her claim, Perez presented Aguinaldo's previous certificates of candidacy for governor in 1988, 1992, and 1995, along with his voter registration records, all indicating his residence in Barangay Calaoagan Dackel, Gattaran, which is outside the Third District.
Aguinaldo countered that he had moved to Tuguegarao, Cagayan, in July 1990, where he rented an apartment to keep his mistress hidden from public view while still married to his first wife. He provided evidence, including an affidavit from his landlord and various documents, to substantiate his claim of residency in Tuguegarao for over a year before the election. On May 10, 1998, the First Division of the COMELEC dismissed Perez's petition, finding Aguinaldo qualified to run. Aguinaldo won the election on May 11, 1998, and was proclaimed on May 16, 1998. Perez filed a motion for reconsideration on May 22, 1998, wh...