Case Summary (G.R. No. 120265)

Background

This case involves a petition for certiorari filed by Agapito A. Aquino against the Commission on Elections (COMELEC) following his disqualification from the position of Representative of the Second Legislative District of Makati City due to alleged lack of residence qualifications required by the Philippine Constitution.

Legal Principle: People's Will and Qualifications of Candidates

• The sanctity of the people's will expressed through elections must be preserved.
• The Court emphasizes the need to uphold the qualifications outlined in the Constitution for candidates, particularly regarding residency.

Key Definitions

• Residence: For the purposes of election law, "residence" is synonymous with "domicile," meaning the place where a candidate has established a permanent home with the intention to remain there.
• Domicile of Choice: A candidate must demonstrate actual residence or domicile in the district for at least one year preceding the election.

Requirements for Candidacy

• Candidates must declare their residence in their Certificate of Candidacy.
• For the position of Representative, candidates must be residents of their respective districts for a minimum of one year prior to the election date.

Procedures and Deadlines

• Filing of Certificate of Candidacy: Candidates must accurately fill out their certificates, providing information about their residence.
• Disqualification Petitions: Any individual or political party can file a petition for disqualification based on the candidate's failure to meet constitutional qualifications.
• Resolution of Disqualification: The COMELEC must resolve disqualification petitions expeditiously, particularly before the election date.

Timeline of Events

• March 20, 1995: Aquino files his Certificate of Candidacy.
• April 24, 1995: Move Makati files a disqualification petition against Aquino.
• May 6, 1995: COMELEC dismisses the disqualification petition and declares Aquino eligible.
• May 15, 1995: COMELEC en banc suspends Aquino’s proclamation after he wins the election.
• June 2, 1995: COMELEC reverses its May 6 decision, declaring Aquino ineligible.

Penalties and Consequences

• Candidates who fail to meet residency qualifications may be disqualified from running for office.
• Votes cast for a disqualified candidate may be deemed invalid, and the candidate with the next highest number of votes may not be automatically proclaimed the winner.

Relevant Laws and Regulations

• 1987 Constitution, Article VI, Section 6: Outlines the qualifications for the House of Representatives, including residency requirements.
• Republic Act No. 6646: Governs the effects of disqualification cases and procedures for resolving disqualification petitions.
• Batas Pambansa Blg. 881 (Omnibus Election Code): Contains provisions regarding the cancellation of certificates of candidacy and disqualification processes.

Key Takeaways

• The Court upheld the importance of constitutional qualifications for candidates, particularly the residency requirement.
• The COMELEC has the authority to suspend the proclamation of a candidate if evidence of disqualification is strong, even after an election.
• Votes

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Case Syllabus (G.R. No. 120265)

Overview of the Case

• Background: The case revolves around the disqualification of Agapito A. Aquino from running for the position of Representative for the Second Legislative District of Makati City due to alleged lack of residency qualifications.
• Petitioner: Agapito A. Aquino.
• Respondents: Commission on Elections (COMELEC), Move Makati, Mateo Bedon, and Juanito Icaro.
• Decision Date: September 18, 1995.
• Decision by: Justice Kapunan.

Context and Legal Framework

• The case is situated within the framework of the Philippine Constitution, specifically Article VI, Section 6, which outlines the requirements for candidates seeking election to the House of Representatives.
• Key Legal Provisions:
  • Candidates must be residents of the district they wish to represent for at least one year preceding the election.
  • The law regarding disqualification cases is governed by Republic Act No. 6646 and the Omnibus Election Code.

Factual Background

• March 20, 1995: Agapito A. Aquino filed his Certificate of Candidacy stating his residence in Palm Village, Makati, and claiming to have resided there for "Years and 10 Months."
• April 24, 1995: Move Makati and Mateo Bedon filed a petition for disqualification against Aquino, asserting he did not meet the residency requirement.
• April 25, 1995: Aquino amended his Certificate of Candidacy, stating he had resided in the constituency for one year and thirteen days.
• May 2, 1995: A hearing was conducted by COMELEC, where Aquino presented evidence supporting his residency claims.

COMELEC Proceedings

• May 6, 1995: The Second Division of the COMELEC dismissed the petition for disqualification, declaring Aquino eligible.
• May 7, 1995: Move Makati filed a Motion for Reconsideration against t

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