G.R. No. 234914 - Rosales vs. Singa Ship Management Phils., Inc.

Florante S. Quizon, the petitioner, was a congressional candidate in the May 14, 2007 national and local elections.
Roberto V. Puno, the private respondent, was also a congressional candidate.
Other respondents include the Commission on Elections (COMELEC) Second Division and election officer Atty. Arnulfo H. Pioquito.

On April 17, 2007, Quizon filed a Petition for Disqualification and Cancellation of Certificate of Candidacy against Puno (docketed as SPA-07-290).
Quizon alleged that Puno failed to meet the residency requirement, claiming Puno’s asserted residence in Antipolo City was false since he was actually residing in Quezon City.
On April 24, 2007, a Supplement to the petition was filed, contending that Puno improperly indicated his candidacy for the First District of the Province of Rizal while campaigning in the First District of Antipolo City—a separate legislative district.

On April 27, 2007, residents of the First District of Antipolo City submitted a letter seeking clarification from COMELEC regarding the apparent discrepancies in Puno’s Certificate of Candidacy (COC).
The letter prayed for Puno’s COC to be declared invalid and cancelled due to the conflicting information on the candidate’s residence and electoral district.

On June 5, 2007, Quizon filed a petition for mandamus to compel the COMELEC Second Division to resolve his pending disqualification petition.
On July 31, 2007, the COMELEC Second Division promulgated a Resolution dismissing the Petition for Disqualification, holding that Puno was a resident of the 1st District of Antipolo City and was, therefore, qualified to run.
Following the resolution, Quizon filed a motion for reconsideration with the COMELEC En Banc, which remained unresolved.

Quizon contended that the COMELEC’s delay in resolving his disqualification petition deprived him of his right to be proclaimed the winning candidate.
He argued that since votes cast for an allegedly invalid candidacy were “stray,” he should be declared the winner, having garnered more votes than his competitor, Amarante Velasco.

Puno argued that the petition for mandamus was moot due to the COMELEC’s prior resolution.
Puno maintained that the issue involved discretionary exercise of power and quasi-judicial functions, precluding a ministerial mandate.

The Solicitor General agreed with Puno that the mandamus petition was already moot because the COMELEC had issued a resolution on the disqualification petition.
It was further asserted that questions regarding Puno’s qualifications now fell within the ambit of the House of Representatives Electoral Tribunal (HRET).

Whether the petition for mandamus is justiciable given that the COMELEC has already resolved the disqualification petition.
Whether the issuance of the COMELEC’s Resolution on July 31, 2007 rendered the mandamus application moot.

Whether a petition for mandamus—which is meant to command the performance of ministerial duties—can be used to compel a resolution in a matter involving discretionary and quasi-judicial functions.
Whether Quizon had demonstrated a clear, well-defined legal right that warranted the issuance of the writ.

Whether the alleged irregularities and the delay in resolving the disqualification petition justify invalidating votes cast for Puno.
Whether a candidate who has not been declared disqualified by final judgment can have his votes deemed “stray” notwithstanding electoral statutes, particularly Section 78 of the Omnibus Election Code.