Title
Provincial Chapter of Laguna, Nacionalista Party vs. Commission on Elections
Case
G.R. No. L-53460
Decision Date
May 27, 1983
A 1980 election case where San Luis, former Laguna Governor, faced disqualification over alleged "turncoatism." The Supreme Court upheld COMELEC's dismissal, ruling no due process violation and no evidence of prohibited party-switching.

Case Digest (G.R. No. L-53460)

Facts:

This is The Provincial Chapter of Laguna, Nacionalista Party (NP) v. Commission on Elections and Felicisimo T. San Luis, G.R. No. 53460, May 27, 1983, the Supreme Court En Banc, Makasiar, J., writing for the Court. In the November 8, 1971 local elections, Felicisimo T. San Luis was elected Governor of Laguna as the official candidate of the Liberal Party (LP); his ordinary four‑year term would have expired on December 31, 1975. On January 18, 1980 the petitioner, the Provincial Chapter of Laguna, Nacionalista Party (NP), filed with the Commission on Elections (COMELEC) a disqualification petition docketed PDC No. 165 seeking to disqualify San Luis from running as the Kilusang Bagong Lipunan (KBL) official candidate for governor on grounds of "turncoatism" under Section 10, Article XII‑C of the 1973 Constitution in relation to Section 4, Batas Pambansa Blg. 52. Parallelly, PDC No. 172 was filed by the Provincial Chapter of Laguna, KBL, against Wenceslao R. Lagumbay (NP official candidate). COMELEC set both petitions for joint hearing on January 24, 1980. The parties filed answers, formal submissions of annexes, and memoranda; San Luis filed a motion for an early favorable resolution on February 4, 1980. On February 21, 1980 COMELEC issued Resolution No. 9188 denying PDC No. 165 for insufficiency of evidence. Petitioner then brought a petition for certiorari to the Supreme Court seeking to annul COMELEC’s dismissal, alleging denial of due process and contending that San Luis had violated b...(Pro-only)

Issues:

  • Was petitioner denied procedural due process by the COMELEC in the disposition of PDC No. 165?
  • Was private respondent Felicisimo T. San Luis disqualified for "turncoatism" under Section 10, Article XII‑C of the 1973 Constitution in relation to Section 4, Batas Pambansa Blg. 5...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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