Case Digest (G.R. No. 221697)
Facts:
Rizalito Y. David v. Senate Electoral Tribunal and Mary Grace Poe-Llamanzares, G.R. No. 221538, September 20, 2016, Supreme Court En Banc, Leonen, J., writing for the Court.Petitioner Rizalito Y. David filed a Petition for Quo Warranto before the Senate Electoral Tribunal (SET) on August 6, 2015 seeking to oust respondent Mary Grace Poe‑Llamanzares from her Senate seat for allegedly not being a natural‑born Filipino, a qualification required by Article VI, Section 3 of the 1987 Constitution. The SET required petitioner to amend formal defects, summoned Poe to answer, subpoenaed records (including Bureau of Immigration and NSO documents), and set a preliminary conference and oral arguments; DNA tests produced no conclusive link to any putative parents. On November 17, 2015 the SET promulgated the challenged Decision dismissing the quo warranto petition and finding Poe a natural‑born citizen; its December 3, 2015 Resolution denied petitioner’s motion for reconsideration.
Mary Grace Poe is a foundling who was discovered at the Parish Church of Jaro, Iloilo on September 3, 1968 and registered with a foundling certificate. She was adopted in 1974 by Ronald Allan Poe (Fernando Poe, Jr.) and Jesusa Sonora Poe. Poe acquired U.S. citizenship by naturalization on October 18, 2001, later took an Oath of Allegiance to the Philippines on July 7, 2006, filed and was granted a Petition for Reacquisition of Philippine citizenship by the Bureau of Immigration on July 18, 2006 under Republic Act No. 9225, and became a registered voter in San Juan on August 31, 2006. She executed an Affidavit of Renunciation of U.S. citizenship on October 20, 2010 and submitted final U.S. loss‑of‑nationality documentation in 2011–2012. Poe filed her certificate of candidacy in 2012, was proclaimed Senator in 2013, and David’s quo warranto proceeded in 2015.
After the SET dispositions, David filed a Rule 65 petition for certiorari in this Court attacking the SET’s November 17, 2015 Decision and December 3, 2015 Resolution; the Court required comments, set oral argument and held the case in abeyance pending ...(Subscriber-Only)
Issues:
- Under Article VI, Section 17 and Article VIII, Section 1 of the Constitution, may this Court, by petition for certiorari under Rule 65, properly review the SET’s decision and, if so, what is the scope of review?
- Did the SET commit grave abuse of discretion amounting to lack or excess of jurisdiction when it found that a foundling — specifically Mary Grace Poe — is a natural‑born Filipino citizen qualified to sit as Senator?
- If Poe is natural‑born, did she validly retain or reacquire Philippine citizenship and satisfy the statutory requisites (under Republic Ac...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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