G.R. No. 231643 - Halili vs. Commission on Elections

Case Summary (G.R. No. 231643)

Case Background and Facts

Marino P. Morales was elected as Mayor of Mabalacat, Pampanga for three consecutive terms from 2007 to 2016, experiencing the municipal-to-city conversion of Mabalacat under RA 10164 in 2012. Morales filed a COC in December 2015 for the 2016 elections as a substitute candidate. Pyra Lucas filed a petition before the COMELEC to cancel Morales’s COC alleging disqualification due to his having served three consecutive terms already—including his term as municipal mayor—which she argued was not interrupted by the city conversion. Crisostomo Garbo and Christian C. Halili, candidates placing second and vice mayor respectively, intervened claiming entitlement to be proclaimed mayor if Morales’s candidacy were cancelled.

COMELEC Resolutions and Rulings

The COMELEC First Division ruled on August 3, 2016, granting Lucas’s petition, canceling Morales’s COC, and declaring all votes cast for him as stray votes, ordering the proclamation of the candidate with the next highest votes (Garbo). The First Division held that Morales committed a material misrepresentation regarding his eligibility due to violation of the three consecutive term limit rule, as his tenure was continuous despite the conversion. The COMELEC En Banc on May 26, 2017, affirmed the First Division's resolution and denied Morales’s motion for reconsideration, reiterating that Garbo should be proclaimed mayor. Execution of this decision was ordered, with Morales directed to cease mayoral functions.

Issues Raised by Petitioners

Halili questioned whether COMELEC erred in proclaiming Garbo instead of declaring a permanent vacancy and applying the succession rule under the Local Government Code. Morales questioned the procedural propriety of the petition against him, arguing (1) that Lucas’s petition was vague and improperly treated as a cancellation petition, (2) that it was filed out of time and without certification against forum shopping, (3) that prior authoritative rulings on his term limits were lacking, (4) that COMELEC lost jurisdiction once he was proclaimed and assumed office, and (5) that the next highest vote-getter should not automatically be proclaimed as winner.

Constitutional and Legal Framework on Term Limits

Section 8, Article X of the 1987 Constitution and Section 43(b) of the Local Government Code prohibit local elective officials from serving more than three consecutive three-year terms in the same position. Voluntary renunciation does not interrupt the continuity of service. The intent is to prevent monopolization of political power and promote voters’ freedom of choice. Two conditions for disqualification based on term limits are that the official must have served three consecutive terms and must have fully served those terms.

Jurisprudence on Conversion of Municipality to City and Term Continuity

The Court relied heavily on precedents (Latasa v. COMELEC; Laceda, Sr. v. Limena) holding that the conversion of a municipality into a city does not interrupt the continuity of an official’s term if the territorial jurisdiction remains the same and the incumbent continues functioning until new elections are held. The territorial jurisdiction of Mabalacat City was declared by law to be the same as the former municipality, and Morales continued exercising mayoral powers uninterrupted. Allegations of increased territory, income, and population without formal resolution of boundary disputes do not alter this legal conclusion.

Findings on Morales’s Eligibility and Material Misrepresentation

Morales admitted he served three consecutive terms as mayor (2007-2016). His claim of interruption due to city conversion was rejected based on clear statutory provisions and established case law. Morales’s certification in his COC declaring his eligibility despite this disqualification constituted a false material representation under Section 78 of the Omnibus Election Code. Precedents (Aratea v. COMELEC; Rivera III v. COMELEC; Dizon v. COMELEC) reaffirmed that a candidate who has served three full consecutive terms cannot validly represent eligibility for a fourth term and that such misrepresentation vitiates the COC.

Procedural Validity of the Petition Against Morales

The Court found the petition filed by Lucas was timely filed within the 25-day period prescribed under Section 78 of the OEC. COMELEC has authority to determine a candidate’s eligibility and can proceed even after proclamation and assumption of office, except in congressional or senatorial cases where jurisdiction shifts to electoral tribunals. The lack of a certification against forum shopping attached to the petition did not invalidate it, as COMELEC procedural rules allow liberal construction in line with its constitutional mandate. The absence of prior authoritative rulings did not bar the COMELEC from making its own factual determinations based on admissions and evidence presented.

Effect of Cancellation of Certificate of Candidacy void ab initio

The Court held that Morales’s COC was void ab initio due to false material representation. Votes cast for him were considered stray votes and thus not counted. Morales was

Case Syllabus (G.R. No. 231643)

Background and Procedural History

This case involves two consolidated petitions seeking to nullify and set aside two resolutions of the Commission on Elections (COMELEC): the Resolution dated August 3, 2016, of the COMELEC First Division, and the Resolution dated May 26, 2017, of the COMELEC En Banc.
Petitioner Marino P. Morales was elected mayor of Mabalacat, Pampanga, from July 1, 2007, to June 30, 2010, re-elected in 2010, and ran again for mayor in 2013 after the municipality’s conversion to a component city under Republic Act No. 10164 in 2012.
Morales filed his Certificate of Candidacy (COC) on December 8, 2015, as a substitute candidate for the May 2016 mayoral election.
Respondent Pyra Lucas filed a Petition for Cancellation of Morales’ COC, alleging violation of the three-term limit rule and asserting that the municipal conversion did not interrupt Morales’ tenure.
Morales filed a verified answer contesting procedural and substantive grounds, notably claiming the city conversion interrupted his service, thus resetting term limits.
Other candidates, Crisostomo Garbo and Christian C. Halili, intervened, asserting their rights to proclamation if Morales’ candidacy were cancelled.
The COMELEC First Division granted the petition, cancelling Morales’ COC, ordered votes cast for him be declared stray, and directed the City Board of Canvassers to proclaim the next highest qualified mayoralty candidate.
The COMELEC En Banc affirmed this ruling, denying Morales’ motion for reconsideration and declaring Garbo as the mayor.
Subsequent motions for temporary restraining orders and other reliefs by Morales and Halili were denied.
The COMELEC En Banc issued a writ of execution ordering Morales to cease mayoral functions and the proclamation of Garbo.
The two petitions for certiorari (G.R. Nos. 231643 and 231657) were consolidated before the Supreme Court.

Factual Context

Republic Act No. 10164 converted Mabalacat from municipality into a component city with territorial jurisdiction within the present metes and bounds of the municipality.
Section 52 of RA 10164 provides that municipal elective officials continue to exercise powers until new elections for city officials occur.
Morales was mayor of Mabalacat from 2007 to 2016 continuously, including after conversion into city status.
Morales’ candidacy for 2016 election allegedly violated the three consecutive term limit rule based on his service continuity despite the municipal conversion.
Morales claimed differences in territorial jurisdiction, population, and income argue for interruption of term continuity.
Evidence of political boundary changes was presented, including a political boundary map not officially released due to ongoing territorial disputes.
Previous jurisprudence addresses similar situations with terms continuity despite municipal conversion.

Issues Presented

In G.R. No. 231643 (Halili):

Whether the COMELEC gravely abused discretion in applying precedent to proclaim Garbo as qualified candidate with the highest votes.
Whether the COMELEC erred in not declaring a permanent vacancy in the mayor’s office after cancelling Morales’ COC.
Whether the COMELEC erred in ordering proclamation of the next highest candidate by the City Board of Canvassers.

In G.R. No. 231657 (Morales):

Whether the COMELEC committed grave abuse by treating Lucas’ petition as one to deny due course despite lack of allegations of deliberate material misrepresentation.
Whether the petition should have been dismissed for procedural de