Case Summary (G.R. No. 221538)
Procedural History
David filed a quo warranto petition with the SET on August 6, 2015, contending that respondent lacked natural-born status and two-year residency. The SET required documentary supplementation, heard oral arguments, and admitted DNA test results that proved inconclusive. On November 17, 2015, the SET dismissed the petition, holding that respondent is a natural-born citizen under Article IV, Section 2 of the 1987 Constitution. A motion for reconsideration was denied on December 3, 2015. David then filed a Rule 65 petition before the Supreme Court, alleging grave abuse of discretion by the SET.
Issue
Did the Senate Electoral Tribunal commit grave abuse of discretion in holding that Mary Grace Poe-Llamanzares, a foundling, is a natural-born citizen qualified to serve as Senator under Article VI, Section 3 of the 1987 Constitution?
Jurisdiction and Standard of Review
The SET has exclusive original jurisdiction over Senatorial qualification contests (Const., Art. VI, Sec. 17). Supreme Court review is limited to certiorari under Rule 65 to determine lack or excess of jurisdiction or grave abuse of discretion by the SET (Const., Art. VIII, Sec. 1). Grave abuse implies a capricious or despotic exercise of judgment in clear disregard of the law.
Citizenship Law and Constitutional Text
Article IV, Section 1 enumerates Filipino citizens by parentage and birth; Section 2 defines natural-born citizens as those “citizens … from birth without having to perform any act to acquire or perfect” citizenship. The 1987 Constitution requires a natural-born status for Senators (Art. VI, Sec. 3). Jus sanguinis is the prevailing principle under Philippine law.
Analysis of Foundling Citizenship
The SET found that, despite unknown parentage, respondent could be reasonably presumed to have Filipino parentage based on: (1) her abandonment as an infant in Iloilo in 1968 when the population was overwhelmingly Filipino; (2) absence of international airports at the discovery site; (3) her physical features; and (4) statistical data showing less than 1% of recorded births in 1968 were to foreigners. The SET concluded that these circumstances support an inference satisfying the substantial-evidence standard before a quasi-judicial body, and that the Constitution’s purpose of protecting children and ensuring equal access to public service demands preventing foundlings’ permanent exclusion from natural-born status.
Supreme Court Ruling
The Supreme Court held that the SET did not exceed its jurisdiction or commit grave abuse of discretion. It affirmed that:
– Constitutional text (Ar
Case Syllabus (G.R. No. 221538)
Facts of the Case
- Mary Grace Poe-Llamanzares was found as a newborn outside the Parish Church of Jaro, Iloilo on September 3, 1968 by Edgardo Militar, who turned her over to Emiliano Militar.
- Registered as a foundling on September 6, 1968 and named Mary Grace Natividad Contreras Militar; a local civil registrar issued a Foundling Certificate.
- Adopted on May 13, 1974 by Ronald Allan Poe (Fernando Poe, Jr.) and Jesusa Sonora Poe (Susan Roces); name changed to Mary Grace Natividad Sonora Poe.
- Education: began Development Studies at University of the Philippines–Manila; earned a B.A. in Political Science from Boston College in 1991.
- Married Teodoro Misael Daniel V. Llamanzares (dual U.S. and Filipino citizen) on July 27, 1991; had three children (Brian, Hanna, Anika) born 1992–2004 in the U.S. and the Philippines.
- Naturalized as a U.S. citizen on October 18, 2001; held a U.S. passport and diplomatic passport until renunciation.
- Returned to the Philippines in 2004–2005 to support her father’s presidential bid and attend to his death in December 2004; resigned U.S. employment in 2004.
- Reacquired Philippine citizenship under R.A. 9225: took Oath of Allegiance on July 7, 2006; petition granted July 18, 2006; received Immigration Identification Certificates July 31, 2006; registered to vote August 31, 2006.
- Appointed Chairperson of the Movie and Television Review and Classification Board (MTRCB) on October 6, 2010; executed affidavits and oaths renouncing U.S. citizenship October 20–21, 2010; Certificate of Loss of Nationality issued December 9, 2011.
- Filed Certificate of Candidacy for Senator in September 2012; declared Senator-elect May 16, 2013.
Procedural History
- August 6, 2015: Petitioner Rizalito Y. David filed a Petition for Quo Warranto before the Senate Electoral Tribunal (SET) to unseat Senator Poe-Llamanzares for alleged failure to meet natural-born citizenship under Article VI, Section 3 of the 1987 Constitution.
- SET issued a series of resolutions to correct formal defects, to summon respondent, and to subpoena records (Immigration, NSO) through September 2015.
- SET conducted a preliminary conference (September 11) and oral arguments (September 21); granted respondent leave to submit DNA evidence (negative) and memoranda.
- November 17, 2015: SET promulgated a Decision dismissing the quo warranto petition, finding respondent a natural-born citizen.
- December 3, 2015: SET denied David’s Motion for Reconsideration.
- December 9, 2015: David filed a Petition for Certiorari under Rule 65 in the Supreme Court challenging SET’s Decision and Resolution for grave abuse of discretion.
- Supreme Court set the case for oral argument January 19, 2016 and held it in abeyance pending a related COMELEC proceeding.
Issue Presented
- Whether the Senate Electoral Tribunal committed grave abuse of discretion amounting to lack or excess of jurisdiction when it dismissed the Petition for Quo Warranto and found private respondent to be a natural-born Filipino citizen qualified to hold the office of Se