G.R. No. 184389 - Madrilejos vs. Gatdula

On January 4, 1980, at 2:45 p.m., petitioner Gelacio I. Yason filed his certificate of candidacy for Mayor of Roxas, Oriental Mindoro with the Municipal Election Registrar.
In Item No. 4 of the form, he initially indicated his political affiliation as “Nationalista (NP).”
Before midnight on the same day, Yason returned to the registrar’s office, obtained his certificate, and made corrections by erasing “Nationalista (NP)” and replacing it with “Kilusang Bagong Lipunan (KBL)” in Item No. 4.
Similarly, in Item No. 5 (which queried if he was nominated by a political party), he erased “Yes” and clearly typed “Kilusang Bagong Lipunan (KBL),” with each alteration being initialed by him.

Around January 10, 1980, the chairman of the Nationalista Party for Oriental Mindoro included Yason’s name in the NP candidate lineup for local positions, allegedly without Yason’s prior knowledge.
On election day, January 30, 1980, upon observing his inclusion in COMELEC’s Certified List of Candidates as a Nationalista, Yason immediately disclaimed affiliation with the NP.
He sent a telegram and a formal letter to COMELEC (with copies furnished to the Roxas Election Registrar), stressing that his candidacy had been filed as a KBL candidate and that he had not authorized any change to NP.

After the canvassing of election returns on February 1, 1980, the municipal board of canvassers certified that Yason received 3,933 votes while his opponent, Lucio T. Suarez, Jr., received 3,568 votes—a margin of 365 votes in favor of Yason.
Despite the clear vote difference, only Yason and a councilor in his lineup were declared winners; the vice-mayoral and most councilor positions favored Suarez’s camp.

On February 2, 1980, respondent Suarez filed a petition for the disqualification of Yason, without furnishing a copy or notice to the petitioner.
On February 4, 1980, COMELEC, without affording Yason an opportunity to contest the petition, issued a resolution denying due course to his candidacy by declaring all votes for him as “stray votes” and proclaiming Suarez as the duly elected mayor.
Yason, upon learning of the resolution, filed a motion for reconsideration and a motion to suspend the proclamation.
On February 13, 1980, COMELEC ordered the citizens’ election committee and the election registrar to adhere to its resolution by treating Yason’s votes as stray and officially proclaiming Suarez.

On February 26, 1980, the Supreme Court issued a restraining order to prevent the enforcement of the contested COMELEC resolutions, later modifying the order to enjoin Suarez from assuming the mayoralty.
On March 18, 1980, respondent Suarez filed a counter-petition, claiming that the municipal board of canvassers had already proclaimed Yason as mayor-elect on March 2, 1980, and sought that such proclamation be set aside.
Underlying all of these proceedings was the issue of “turncoatism,” referring to the alleged change of party affiliation by Yason, which raised constitutional questions regarding the validity of his candidacy.

Whether COMELEC, after the proper canvassing and proclamation of votes, retained the power to cancel a certificate of candidacy or disqualify a candidate on the ground of altering party affiliation.
Whether the petition for disqualification (alleging turncoatism) was filed in a timely manner, in accordance with prescribed deadlines.

Whether the corrections made by Yason on his certificate of candidacy, which clearly indicated his affiliation with KBL, are valid and binding despite the earlier indication of affiliation with the NP.
Whether Yason’s subsequent communications (telegram and letter) contesting the inclusion in the NP lineup sufficiently confirm his intent to run as a KBL candidate.

Whether the actions of Yason constitute “turncoatism” under Section 10, Article XII-C of the 1973 Constitution as then applied, considering he did not formally affiliate with the NP through membership or oath-taking.
How the constitutional prohibition against turncoatism should be interpreted in light of the need to respect voter intent and the electoral process.