Case Digest (G.R. No. 198756) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Petitioner Edgar Y. Teves, then mayor of Valencia and candidate for Representative of the 3rd District of Negros Oriental in the May 14, 2007 elections, was previously convicted by the Sandiganbayan in Teves v. Sandiganbayan (488 Phil. 311 [2004]) for violating Section 3(h) of R.A. No. 3019 by possessing a pecuniary interest in a cockpit prohibited under Local Government Code Section 89(2). He was sentenced to pay a fine of ₱10,000.00. On March 30, 2007, respondent Herminio G. Teves filed a petition with the Commission on Elections (COMELEC) to disqualify Edgar Teves from candidacy on the ground that his conviction involved moral turpitude, carrying the accessory penalty of perpetual disqualification under Section 12 of the Omnibus Election Code. The First Division of COMELEC disqualified him on May 11, 2007 and cancelled his Certificate of Candidacy. Petitioner’s motion for reconsideration before the COMELEC en banc was denied by Resolution of October 9, 2007 as moot, citing hi Case Digest (G.R. No. 198756) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the case
- Edgar Y. Teves, then Mayor of Valencia, Negros Oriental, ran for Representative of the 3rd District of Negros Oriental in the May 14, 2007 elections.
- In Teves v. Sandiganbayan (488 Phil. 311, 2004), he was convicted under Section 3(h) of R.A. 3019 for possessing a pecuniary interest in a cockpit prohibited by Section 89(2) of the LGC, and was fined ₱10,000.00.
- COMELEC proceedings
- On March 30, 2007, Herminio G. Teves filed a petition with the COMELEC First Division to disqualify Edgar Teves on grounds that his conviction involved moral turpitude and thus carried perpetual disqualification.
- On May 11, 2007, the First Division disqualified Edgar Teves and cancelled his Certificate of Candidacy.
- Edgar Teves moved for reconsideration before the COMELEC en banc; on October 9, 2007, the en banc denied the motion as moot since he had already lost the election.
- Petition before the Supreme Court
- Edgar Teves petitioned the Supreme Court asserting:
- The en banc erred in not resolving whether his conviction involved moral turpitude.
- The issue was not moot since it affects eligibility in future elections.
- The COMELEC wrongly held that his conviction under R.A. 3019 §3(h) and fine constituted moral turpitude.
- The Supreme Court noted that Teves paid the fine on May 24, 2005, and the five-year disqualification period would end on May 25, 2010—after the May 14, 2010 elections—making the issue justiciable.
Issues:
- Does petitioner’s conviction under R.A. 3019 §3(h) involve moral turpitude?
- Did the COMELEC en banc abuse its discretion by dismissing the motion for reconsideration as moot?
- Would the five-year disqualification period have expired before the May 14, 2010 elections?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)