Case Digest (G.R. No. L-13069)
Facts:
Jovencio A. Reyes v. Commission on Elections and Godofredo S. Reyes, G.R. No. L-13069. May 28, 1958, the Supreme Court En Banc, Labrador, J., writing for the Court.Jovencio A. Reyes (petitioner) was a registered candidate in the 1957 general elections for Congressman of the Second District of Ilocos Sur; his certificate of candidacy was filed on August 20, 1957 and the Commission on Elections initially informed him it would be given due course. On September 22, 1957, Godofredo S. Reyes (respondent) filed a petition with the Commission praying that petitioner’s certificate be cancelled on the ground that it was presented in bad faith.
The Commission ordered an investigation, and after hearing found that petitioner had conducted little or no campaigning within the district: only one small poster, no house-to-house canvassing, no political meetings or rallies in the district from filing up to October 27, 1957, and that petitioner was actually residing in Quezon City. On the basis of these facts the Commission concluded the certificate was filed in bad faith and refused to give it due course.
When the petition was presented to the Supreme Court, the Court granted a preliminary injunction directing the Commission to give due course to the certificate. The case was called for hearing on November 9; petitioner appeared in person and, acting as his own counsel, argued and answered the Court’s inquiries. The Court declared itself satisfied that petitioner possessed the requisite legal qualifications for the office.
The Supreme Court reviewed the Commission’s action, applying prior decisions such as Abcede v. Hon. Domingo Imperial and distinguishing Ciriaco S. Garcia v. Imperial (G.R. No. L-12930). The Court concluded...(Pro-only)
Issues:
- Did the Commission on Elections have jurisdiction or discretion to refuse to give due course to petitioner’s certificate of candidacy on the ground that it was filed in bad faith because the candidate did not campaign in the ordinary forms?
- Was petitioner’s certificate of candidacy filed in bad faith such that the Commission properly ref...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)