Case Summary (G.R. No. 207105)

Disqualification of Dual Citizens from Public Office

• A person with dual citizenship is disqualified from running for public office in the Philippines.
• The case revolves around the petitioner's eligibility to run for Mayor of Marcos, Ilocos Norte, after being naturalized as a U.S. citizen in 1997.
• The Commission on Elections (COMELEC) ruled against the petitioner, leading to the cancellation of his Certificate of Candidacy (CoC).

Background of the Case

• The petitioner filed his CoC on October 5, 2012, claiming to be a natural-born Filipino citizen and a resident of Marcos for 25 years.
• A rival candidate, Salvador S. Pillos, contested the CoC, alleging material misrepresentation regarding the petitioner's residency.
• The petitioner argued that residency is not contingent on voter registration and provided an Affidavit of Renunciation of U.S. citizenship.

COMELEC's Initial Ruling

• The COMELEC Second Division ruled that the petitioner's voter registration status did not invalidate his CoC.
• The ruling emphasized that the requirement for voter registration does not necessitate a one-year residency prior to the election.
• The petitioners failed to provide evidence that the respondents were residents of other countries.

Motion for Reconsideration and Subsequent Rulings

• Pillos filed a motion for reconsideration, highlighting the petitioner's use of a U.S. passport after renouncing his citizenship.
• The COMELEC En Banc ultimately canceled the petitioner's CoC, stating he failed to prove compliance with the requirements for dual citizens under Republic Act 9225.

Petitioner’s Subsequent Actions

• The petitioner filed a Verified Urgent Motion for Reconsideration, providing additional documents to support his claim of compliance with Philippine citizenship requirements.
• Despite the ongoing legal proceedings, the petitioner was proclaimed the duly elected Mayor on May 13, 2013, receiving the highest number of votes.

Legal Issues Raised

• The core issue was the petitioner's eligibility to run for mayor, with a secondary issue regarding Pillos' claim to the position.
• The petitioner alleged grave abuse of discretion by the COMELEC, claiming violations of his constitutional rights and erroneous legal interpretations.

Court's Ruling on Due Process

• The Court found that the COMELEC did not violate the petitioner's right to due process, as he had the opportunity to defend himself.
• The Court noted that due process in administrative proceedings does not require a trial-type hearing.

Validity of the Certificate of Candidacy

• The Court acknowledged that the petitioner filed a valid CoC but highlighted that his use of a U.S. passport after renouncing his citizenship disqualified him from candidacy.
• The distinction between petitions for disqualification and petitions to deny due course to a CoC was clarified.

Misrepresentation and Disqualification

• The Court emphasized that a material misrepresentation must involve a deliberate attempt to mislead regarding a candidate's qualifications.
• The COMELEC's basis for canceling the CoC was d...continue reading