G.R. No. 258456 - Aggabao vs. Commission on Elections

Giorgidi B. Aggabao and Amelita S. Navarro filed a Petition for Certiorari against the Commission on Elections (COMELEC) to nullify three documents issued by the COMELEC Law Department.
The documents in question include:
- Document No. 21-3973, declaring Navarro as an independent candidate.
- Document No. 21-7467, denying Aggabao's Certificate of Candidacy (COC) as a substitute candidate for Navarro.
- Document No. 22-0176, denying Aggabao's motion for reconsideration.
The petitioners also sought a temporary restraining order (TRO) to prevent their exclusion from the ballot pending resolution of the case.

Navarro filed her COC for Mayor of Santiago City, Isabela, claiming nomination by the Partido para sa Demokratikong Reporma (Partido Reporma).
Another candidate, Christopher G. Ayson, also filed a COC for the same position, claiming nomination by the same party.
Senator Panfilo M. Lacson, Chairperson of Partido Reporma, sent a letter to COMELEC disavowing Ayson's nomination, asserting that Navarro was the official candidate.

On November 9, 2021, Navarro withdrew her candidacy for Mayor and opted to run for Vice-Mayor, stating that Aggabao would substitute her for the mayoralty position.
Aggabao filed his COC as a substitute candidate, claiming official nomination by Partido Reporma.

The COMELEC declared Navarro an independent candidate due to multiple nominations from the same party, as per Section 15 of COMELEC Resolution No. 10717.
Aggabao clarified Navarro's withdrawal and his substitution in a letter to the COMELEC, referencing Senator Lacson's disavowal of Ayson's CONA.

On December 22, 2021, the COMELEC maintained that Navarro was an independent candidate and denied Aggabao's COC as a substitute.
The COMELEC's certified list of candidates for the May 9, 2022 elections did not include Aggabao as a mayoralty candidate, while Ayson was listed as an independent candidate.

Aggabao filed a motion for reconsideration, which was denied by the COMELEC, reiterating that both Navarro and Ayson were independent candidates and that Aggabao's COC could not be given due course.

Aggabao and Navarro alleged that the COMELEC acted with grave abuse of discretion by declaring Navarro an independent candidate and denying Aggabao's substitution without due process.
They contended that the COMELEC incorrectly applied Section 15 of the resolution, as Partido Reporma did not nominate more than one candidate.

The Court issued a TRO on January 25, 2022, enjoining the COMELEC from enforcing the document that denied Aggabao's candidacy.

In its comment, the COMELEC maintained that it had received two COCs with CONAs for the mayoralty position, leading to the declaration of both candidates as independent.
The COMELEC argued that since Navarro was an independent candidate, Aggabao could not substitute her.

The Court found the petition moot due to the conclusion of the May 9, 2022 elections, which resulted in the election of a different candidate.
However, the Court noted that it could still render a decision due to the potential for grave constitutional violations and the public interest involved.

The COMELEC's powers are classified into administrative, quasi-legislative, and quasi-judicial functions.
The quasi-judicial power includes resolving controversies arising from election laws and conducting hearings on election-related disputes.

The COMELEC has a ministerial duty to receive and acknowledge COCs and CONAs filed in due form.
However, when a legal controversy arises, the COMELEC is required to exercise its quasi-judicial functions, which include conducting hearings and weighing evidence.

The COMELEC failed to act on Senator Lacson's letters challenging Ayson's CONA, which c...continue reading