G.R. No. L-8014 - Vilar vs. Paraiso

The case involves the municipal elections held on November 13, 1951, in Rizal, Nueva Ecija for the office of mayor.
Two candidates, Pedro V. Vilar (petitioner) and Gaudencio V. Paraiso (respondent), participated in the elections.
The canvassing of votes resulted in Vilar obtaining 1,467 votes while Paraiso garnered 1,509 votes, leading to the proclamation of Paraiso as mayor-elect with a plurality of 41 votes.

Petitioner Vilar contended that Paraiso was ineligible to hold the office of mayor because he was an active minister of the United Church of Christ in the Philippines.
The basis of the disqualification lies in section 2175 of the Revised Administrative Code which prohibits ecclesiastics from running for municipal office.
Vilar instituted quo warranto proceedings demanding the nullification of Paraiso’s proclamation and asserting his own election as mayor.

Documents and testimony showed that respondent was ordained as minister of the Evangelical Church of the Philippines in 1944.
He continuously served as minister in Rizal from 1944 up to 1950, renewing his license to solemnize marriages as required by the Bureau of Public Libraries.
In April 1950, he transferred to the United Church of Christ in the Philippines and continued his ministerial functions, evidenced by his license issued on April 7, 1951, valid until the end of April 1952.
Despite the transfer, no cancellation of the ministerial license was executed, and respondent was publicly recognized as an active minister.
Importantly, he failed to attach a certified copy of his purported resignation as minister to his certificate of candidacy.

Respondent claimed that he filed his resignation as minister of the United Church of Christ on August 21, 1951, motivated by his desire to venture into politics.
He further maintained that his resignation was accepted by his church’s cabinet at a special meeting held in Polo, Bulacan on August 27, 1951.
He asserted that he had turned over his chapel and office to senior members of his religious order, thereby severing his active ministerial ties.

At trial, the court evaluated the credibility and weight of the evidence for both parties.
The trial court found that respondent never effectively ceased to function as an ecclesiastic.
It characterized the alleged resignation as a mere scheme devised to circumvent the statutory prohibition against ecclesiastics running for municipal office.
Consequently, the trial court declared respondent’s proclamation as mayor-elect null and void, but it refrained from declaring petitioner as the duly elected mayor due to lack of legal grounds.

Both parties appealed the decision: respondent contested his ineligibility whereas petitioner contested the inability to be declared elected.
The Court of Appeals observed that the appeals, though intertwined in a single case involving both questions of fact and law, were indivisible.
The case was then certified to the Supreme Court under sections 17 and 31 of the Judiciary Act of 1948, given that one of the appeals raised a question exclusively within the Supreme Court’s cognizance.

Whether Gaudencio V. Paraiso, being an ecclesiastic, is disqualified from holding the municipal office of mayor under section 2175 of the Revised Administrative Code.

The determination hinges on whether the evidence supports that respondent continued his ministerial functions despite claims of resignation.
It involves evaluating the credibility of the evidence concerning his ministerial activities and the procedural propriety of his alleged resignation.

Whether, in light of the respondent’s alleged disqualification, Pedro V. Vilar, who secured the second-highest number of votes, can be declared the duly elected mayor.

This issue considers if the law permits the declaration of the runner-up as the elected candidate in the event of the disqualification of the candidate receiving the highest number of votes.
The matter requires analysis of electoral provisions and precedents to determine whether such substitution is legally valid.