Case Summary (G.R. No. L-55413)
Facts of the Case
On January 4, 1980, Farinas filed a certificate of candidacy with the election registrar of Laoag City for the position of mayor under the Nacionalista Party. Later that same day, he filed another certificate of candidacy with the Comelec indicating he was running as the official KBL candidate and withdrew his earlier candidacy. On January 8, 1980, Ernesto T. Farinas confirmed Rodolfo as the KBL's candidate for mayor. On January 20, 1980, Laoag City was declared a free zone for the KBL, leading Antonio F. Lazo to file a petition for disqualification against Farinas for his dual candidacy.
Proceedings Before Comelec
Antonio F. Lazo submitted a petition for disqualification against Farinas on January 20, 1980, which was served to Farinas. Farinas submitted an unverified answer on January 25, 1980, and a verified answer on January 28, 1980, the same day the Comelec heard the case. The Comelec issued Resolution No. 8547, disqualifying Farinas on the grounds of "turncoatism" and engaging in partisan political activities prior to the campaign, citing relevant Presidential Decrees.
Election Outcome
Despite the Comelec's disqualification resolution, Farinas was proclaimed the winner of the mayoral election on February 6, 1980, with a margin of 6,419 votes over Lazo. This proclamation occurred after the Comelec lifted its suspension order.
Motion to Withdraw Petition
On February 13, 1980, Farinas filed a motion to withdraw his petition against the Comelec's resolution, arguing that it had become moot due to his proclamation as mayor. The Comelec, through the Solicitor General, and Lazo expressed that the case was not moot despite the proclamation.
Court's Direction for Reevaluation
The court determined that the previous hearing before Comelec was inadequate to thoroughly examine the facts of the case due to its summary nature. It noted that the parties were not provided with a proper opportunity to present their cases or to submit memoranda. The court's
...continue readingCase Syllabus (G.R. No. L-55413)
Case Background
- Rodolfo C. Farinas, aged 28, filed his certificate of candidacy for mayor of Laoag City on January 4, 1980, representing the Nacionalista Party.
- On the same day, he submitted another certificate of candidacy to the Commission on Elections (Comelec), declaring himself the official candidate of the Kilusang Bagong Lipunan (KBL) for the same position.
- Farinas communicated his withdrawal from the Nacionalista Party candidacy, claiming it was filed in error.
- On January 8, 1980, Ernesto T. Farinas informed the provincial election registrar that Rodolfo was heading the KBL ticket in Laoag City.
Events Leading to Disqualification
- On January 20, 1980, Laoag City was declared a free zone for KBL.
- Antonio F. Lazo, a fellow KBL candidate, filed a petition with the Comelec to disqualify Farinas based on his dual candidacies.
- Farinas received a copy of Lazo’s petition and responded on January 25, 1980, but his answer was not verified.
Comelec Proceedings
- The hearing on the disqualification petition was held on January 26, 1980, without oral evidence being presented.
- The parties submitted their pleadings and supporting annexes as exhibits.
- On January 2