Title
Poe-Llamanzares vs. Commission on Elections
Case
G.R. No. 221697
Decision Date
Mar 8, 2016
Mary Grace Poe-Llamanzares, a foundling, reacquired Philippine citizenship and ran for president; the Supreme Court ruled her residency and citizenship claims were in good faith, overturning COMELEC's cancellation of her candidacy.

Case Digest (G.R. No. 221697)

Facts:

Mary Grace Natividad S. Poe-Llamanzares, petitioner, was found abandoned as a newborn on 3 September 1968 at the Parish Church of Jaro, Iloilo. Her foundling certificate and certificate of live birth were issued in Iloilo City on 6 September 1968, and she was later adopted by Ronald Allan Kelley Poe and Jesusa Sonora Poe under a decision of the Municipal Trial Court of San Juan City dated 13 May 1974, which changed her name to Mary Grace Natividad Sonora Poe. She later registered as a voter in San Juan City, received Philippine passports, studied in the Philippines and abroad, and married Teodoro Misael Daniel V. Llamanzares on 27 July 1991. After living in the United States, where she became a naturalized American citizen on 18 October 2001, she returned to the Philippines on several occasions and, by her account and supporting evidence, permanently resettled here on 24 May 2005 with her family. She took an oath of allegiance under R.A. No. 9225 on 7 July 2006, filed a petition for reacquisition of Philippine citizenship on 10 July 2006, and the Bureau of Immigration issued an order on 18 July 2006 recognizing her reacquisition of Philippine citizenship and the citizenship of her minor children. She was later appointed Chairperson of the MTRCB, executed renunciation documents respecting her American citizenship, filed a Certificate of Candidacy for Senator on 2 October 2012, and filed a Certificate of Candidacy for President on 15 October 2015, where she declared herself a natural-born citizen and stated that she had been a resident of the Philippines for 10 years and 11 months. Private respondents Estrella C. Elamparo, Francisco S. Tatad, Antonio P. Contreras, and Amado D. Valdez separately filed petitions before the COMELEC to deny due course to or cancel her certificate of candidacy. The COMELEC’s Second Division and First Division granted the petitions and cancelled her COC, and the COMELEC En Banc den...(Subscriber-Only)

Issues:

Was Mary Grace Natividad S. Poe-Llamanzares guilty of material misrepresentation in her Certificate of Candidacy as to natural-born citizenship and the ten-year residency requirement for President?

Did the COMELEC commit grave abuse of discretion in cancelling her Certificate of Candidacy and in passing upon her qualifications ...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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