Case Digest (G.R. No. 264352) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Regina Ongsiako Reyes v. Commission on Elections and Joseph Socorro B. Tan (G.R. No. 207264, October 22, 2013), petitioner Regina Ongsiako Reyes sought judicial relief after the COMELEC cancelled her Certificate of Candidacy (COC) for Representative of the lone district of Marinduque. On March 27, 2013, the COMELEC First Division found that Reyes committed false material misrepresentation in her COC by failing to prove her Filipino citizenship and residency, and thus cancelled her COC. Reyes moved for reconsideration, but on May 14, 2013 the COMELEC En Banc denied her motion, rendering the cancellation final and executory five days thereafter. Despite this, on May 18, 2013 the Marinduque Provincial Board of Canvassers proclaimed Reyes as the election winner, and she took her oath of office on June 5 and again on June 27, 2013. On June 10, 2013, Reyes filed an original and special civil action for a writ of certiorari with prayer for injunctive relief before the Supreme Court, Case Digest (G.R. No. 264352) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties
- Regina Ongsiako Reyes – petitioner; candidate for Member of the House of Representatives, lone district of Marinduque; proclaimed winner and took oath.
- Commission on Elections (COMELEC) and Joseph Socorro B. Tan – respondents; Tan moved to cancel Reyes’s certificate of candidacy (CoC).
- COMELEC proceedings and key dates
- October 10, 2012: Tan files petition to deny due course to or cancel Reyes’s CoC for alleged false representation of citizenship and residency.
- March 27, 2013: COMELEC First Division grants Tan’s petition; cancels Reyes’s CoC.
- April 8, 2013: Reyes moves for reconsideration; May 14, 2013: COMELEC en banc denies it.
- May 18, 2013: Provincial Board of Canvassers (PBOC) proclaims Reyes winner, despite COMELEC en banc decision.
- June 5, 2013: COMELEC issues “Certificate of Finality,” declaring May 14 resolution final and executory.
- Supreme Court and subsequent events
- June 10, 2013: Reyes files petition for certiorari with prayer for TRO/PI; June 25, 2013: Supreme Court dismisses petition.
- July 9, 2013: COMELEC en banc annuls Reyes’s proclamation; proclaims Tan.
- July 22, 2013: 16th Congress convenes; Reyes takes oath in open session before Speaker.
Issues:
- Jurisdiction
- Whether COMELEC had jurisdiction to cancel Reyes’s CoC and whether its May 14, 2013 decision became final before Reyes’s proclamation.
- Whether Reyes’s proclamation, oath, and assumption of office divested COMELEC of jurisdiction in favor of the House of Representatives Electoral Tribunal (HRET).
- Due process and evidence
- Whether COMELEC violated Reyes’s right to due process by admitting hearsay and uncertified documents in summary proceedings.
- Citizenship qualification
- Whether Reyes validly reacquired Filipino citizenship under RA 9225 (dual citizenship law) and was thus qualified to run for office.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)