Case Summary (A.C. No. 6297)
Background of the Case
Blanco's disqualification history began with the 1995 elections, where he was found administratively liable for vote-buying, leading to his suspension. This was upheld by the Supreme Court in 1997. As Blanco continued to run for mayor in subsequent elections (1998, 2001, and 2004), he faced challenges based on his prior disqualification. Despite the arguments against him, the Commission on Elections (COMELEC) dismissed disqualification petitions in 1998 but ruled against him in 2001 and 2007 based on his earlier infractions.
Disqualification Basis
During the May 14, 2007 elections, Blanco was once again disqualified under resolutions citing his previous disqualification in a 1995 election and a later ruling asserting he had been removed from office through an administrative case. The COMELEC held that since Blanco failed to provide evidence of receiving a presidential pardon or clemency, his disqualifications remained applicable.
Procedural Issues
One significant legal point addressed was whether the Supreme Court could take jurisdiction over the case given that Blanco did not file a motion for reconsideration with the COMELEC en banc as required for certiorari. Precedents indicated that this procedural requirement could be overlooked to prevent miscarriage of justice, particularly when issues of public interest arise, allowing the Court to rule directly on Blanco's petition.
Evaluation of Disqualification Claims
Blanco argued that his disqualification in the 1995 elections only applied to that election, citing that no criminal prosecution had followed for vote-buying, and thus, the subsequent elections should not be impacted by this earlier allegation. The Supreme Court found merit in this argument, noting that his prior disqualification was based solely on an electoral aspect determined through administrative proceedings, distinct from a criminal conviction that would invoke more stringent disqualification protocols.
Conclusion on COMELEC’s Grave Abuse of Discretion
The Supreme Court ultimately held that the COMELEC had committed grave abuse of discretion in disqualifying Blanco based on interpretations of the Omnibus
...continue readingCase Syllabus (A.C. No. 6297)
Case Background
- The case revolves around a petition for certiorari filed by Florentino P. Blanco against the Commission on Elections (COMELEC) and Eduardo A. Alarilla, stemming from a resolution issued by the COMELEC on August 28, 2007, disqualifying Blanco from running for an elective office in the May 14, 2007 elections.
- Blanco previously served as the mayor of Meycauayan, Bulacan, from 1987 to 1992 and won the mayoralty position in the May 8, 1995 elections. However, his victory was contested by Alarilla, who filed a disqualification petition based on allegations of vote-buying.
Previous Disqualifications
- On August 15, 1995, the COMELEC disqualified Blanco due to a violation of Section 261(a) of the Omnibus Election Code concerning vote-buying.
- The Supreme Court affirmed this disqualification in the case of Blanco vs. COMELEC (G.R. No. 122258) on July 21, 1997.
- In subsequent elections (1998, 2001, and 2004), Blanco faced additional disqualifications based on the earlier ruling, but the COMELEC later ruled that his disqualifications were not applicable to elections after 1995 due to the nature of the findings.
Declaratory Relief and Subsequent Elections
- To clarify his eligibility for future elections, Blanco sought a declaratory relief from the Regional Trial Court (RTC) of Malolos, which declared him eligible to run