G.R. No. 119976 - Romualdez-Marcos vs. Commission on Elections

On March 8, 1995, Imelda Romualdez-Marcos filed her CoC for Representative of the First District of Leyte, stating under item no. 8: “RESIDENCE IN THE CONSTITUENCY WHERE I SEEK TO BE ELECTED IMMEDIATELY PRECEDING THE ELECTION: ____ Years and Seven Months.”
Incumbent Cirilo Roy Montejo, also a candidate, alleged in his voter registration record (six months in Tolosa as of January 28, 1995) and the CoC entry (seven months) that she lacked the required one-year residency.

On March 23, 1995, Montejo filed with the COMELEC a “Petition for Cancellation and Disqualification,” asserting petitioner failed the one-year residency requirement.
On March 29, 1995, Mrs. Marcos submitted an amended CoC changing “seven months” to “since childhood,” which the Provincial Election Supervisor rejected as untimely.
On March 31, 1995, petitioner filed her amended CoC and her Answer to Montejo’s petition at the COMELEC head office, claiming an “honest misinterpretation” and reaffirming Tacloban City as her domicile.

April 24, 1995: The COMELEC Second Division (2–1) found Montejo’s petition meritorious, struck off the amended CoC, and cancelled the original CoC for failure to meet residency.
May 7, 1995: The COMELEC en banc denied petitioner’s Motion for Reconsideration, finding no new substantial matters.
May 11, 1995: The COMELEC first allowed her proclamation if she obtained the highest votes, then immediately directed suspension of her proclamation should she win.

May 14, 1995: Provincial Board of Canvassers certified petitioner’s landslide victory (70,471 votes vs. Montejo’s 36,833).
May 25, 1995: Petitioner filed a Supplemental Petition in the Supreme Court seeking relief from the COMELEC’s disqualification orders and for direction to proclaim her winner.

Whether Mrs. Marcos satisfied the Constitution’s one-year residency requirement as a candidate for the House of Representatives.

Whether the COMELEC validly exercised jurisdiction to disqualify petitioner pre- and post-election under the Omnibus Election Code.
Whether, after the May 8, 1995 elections, the House of Representatives Electoral Tribunal (HRET) had exclusive jurisdiction over challenges to a candidate’s qualifications.