Case Summary (G.R. No. 258456)
Petitioners and Respondents
• Petitioners: Aggabao and Navarro seeking nullification of COMELEC documents and reinstatement of Aggabao’s candidacy.
• Respondents: COMELEC En Banc and its Law Department.
Key Dates
• Oct 4, 2021 – Navarro files COC for Mayor with CONA signed by Lacson.
• Oct 8, 2021 – Ayson files COC and CONA also signed by Lacson.
• Nov 6, 2021 – Lacson’s letter and notarized certification disavow Ayson’s CONA, affirm Navarro as sole nominee.
• Nov 9, 2021 – Navarro withdraws; Aggabao files as her substitute with CONA dated Nov 8.
• Nov 10, 2021 – Document No. 21-3973 declares Navarro independent.
• Dec 22, 2021 – Document No. 21-7467 withdraws Navarro’s COC and denies Aggabao’s substitution.
• Jan 5, 2022 – Document No. 22-0176 denies motion for reconsideration.
• Jan 25, 2022 – Supreme Court issues TRO against enforcement of Dec 22 document.
• May 9, 2022 – National and Local Elections held; petition rendered moot by outcome.
Applicable Law
• 1987 Constitution, Article IX-C – COMELEC’s administrative, quasi-legislative, and quasi-judicial powers; hearing and decision rules.
• Omnibus Election Code (B.P. 881) § 76 – ministerial duty to receive and acknowledge COCs.
• COMELEC Resolution No. 10717 §§ 15, 32, 39–40 – rules on nominations, ministerial duties, substitution, and number of allowed nominations.
Factual Background
Navarro filed her COC as Partido Reporma’s mayoral nominee, attaching a CONA signed by Lacson. Ayson filed a similar COC/CONA. Lacson then disavowed Ayson’s CONA and confirmed Navarro as the party’s only nominee. Navarro withdrew and designated Aggabao as substitute, supported by a new CONA from Lacson.
COMELEC Dispositions
COMELEC Law Department Document No. 21-3973 declared Navarro independent for multiple nominations. The En Banc maintained that Navarro’s withdrawal did not cure the defect and denied Aggabao’s substitution (Doc. Nos. 21-7467 and 22-0176). The certified list omitted Aggabao and listed both Navarro and Ayson as independents.
Petitioners’ Assertions
• Violation of due process – denial of substitution without prior hearing.
• Misapplication of Section 15 – Partido Reporma nominated only one candidate; Ayson’s CONA was fraudulent.
• Valid substitution – Navarro’s initial nomination allowed Aggabao’s substitution under OEC § 77 and Com Res No. 10717 § 40.
Proceedings Below and TRO
Petitioners filed certiorari under Rule 64. The Supreme Court issued a TRO (Jan 25, 2022) enjoining enforcement of the Dec 22, 2021 document. COMELEC continued election preparations, generating ballots by Jan 9, 2022.
COMELEC’s Justification
In its comment, COMELEC asserted it merely performed its ministerial duty in accepting notarized CoCs and CONAs. It argued that once Navarro was deemed independent, no substitution was allowed. It explained non-compliance with the TRO by reference to strict election preparation timelines and a technical cut-off date of Jan 9, 2022 for ballot generation.
Supreme Court’s Analysis – Mootness
The May 9, 2022 election results made the petition’s prayers to admit Aggabao’s COC and include his name moot. However, the Court invoked the exception to address controlling principles to guide future COMELEC action.
Supreme Court’s Analysis – Quasi-Judicial Duty and Due Process
• Receipt of CoCs/CONAs is ministerial; initial acceptance was proper.
• Lacson’s letters disavowing Ayson’s CONA created a legal controversy requiring COMELEC to look beyond the documents’ face, investigate, hear conflicting claims, and weigh evidence.
• Such adjudication demands exercise of COMELEC’s quasi-judicial powers, which must be carried out by its Divisions with notice and hearing, then by the En Banc on reconsideration.
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Case Syllabus (G.R. No. 258456)
Facts of the Case
- On October 4, 2021, Amelita S. Navarro filed her Certificate of Candidacy (COC) for Mayor of Santiago City, Isabela for the May 9, 2022 elections, claiming nomination by Partido para sa Demokratikong Reporma (Partido Reporma) and attaching a notarized Certificate of Nomination and Acceptance (CONA) dated September 23, 2021 signed by Senator Panfilo M. Lacson, party chair.
- On October 8, 2021, Christopher G. Ayson also filed a COC for the same post, likewise declaring nomination by Partido Reporma and submitting a same-dated CONA bearing Senator Lacson’s signature.
- On November 6, 2021, Senator Lacson sent a letter and attached certification to the COMELEC Law Department disavowing any CONA issued to Ayson, affirming Navarro as the sole official Partido Reporma candidate for Mayor, and requesting correction of COMELEC records.
- On November 9, 2021, Navarro withdrew her COC for Mayor and opted to run for Vice-Mayor; on the same day, Giorgidi B. Aggabao filed his COC as Navarro’s substitute, attaching a CONA dated November 8, 2021 signed by Senator Lacson.
Commission on Elections Dispositions
- Document No. 21-3973 (November 10, 2021): COMELEC Law Department declared Navarro an independent candidate under Section 15 of COMELEC Resolution No. 10717, citing multiple nominations by the same party for one position.
- Document No. 21-7467 (December 22, 2021): COMELEC En Banc maintained Navarro’s independent status and denied due course to Aggabao’s COC as substitute, reasoning that substitution is not allowed for independent candidates.
- Document No. 22-0176 (January 5, 2022): COMELEC denied Aggabao’s motion for reconsideration, reiterating the independent-candidate ruling and labeling the motion as a prohibited pleading under COMELEC procedural rules.
Petitioners’ Allegations and Prayer
- Petitioners Aggabao and Navarro filed a petition for certiorari under Rule 64, alleging grave abuse of discretion by COMELEC in:
- Declaring Navarro independent despite Senator Lacson’s letters disavowing Ayson’s CONA.
- Denying Aggabao’s valid substitution as official Partido Reporma candidate.
- Failing to hold any proceedings on competing CONAs before any COMELEC division.
- They prayed to nullify the three assailed documents and to restrain Aggabao’s exclusion from the ballot pending final resolution.
Procedural Chronology
- January 25, 2022: Supreme Court issued a temporary restraining order (TRO) enjoining COMELEC from enforcing Document No. 21-7467.
- February