G.R. No. L-60504 - IN RE: Geronimo vs. Ramos

The petitions arise from the 1980 mayoralty elections in Baras, Rizal, where Meliton C. Geronimo was elected but later disqualified due to political turncoatism.
Julian Pendre filed a petition with the Commission on Elections (COMELEC) to disqualify Geronimo, leading to COMELEC's Resolution No. 8305 on January 19, 1980, disqualifying him.
Geronimo sought a temporary restraining order from the Supreme Court, which was granted, allowing him to run in the elections where he won by a margin of 325 votes.
The Supreme Court later affirmed Geronimo's disqualification, leading to further legal actions and controversies regarding his election and subsequent actions.

Following the Supreme Court's decision, COMELEC issued Resolution No. 82-428, nullifying Geronimo's candidacy and declaring all votes for him as "stray."
Geronimo's attempts to contest this resolution were denied, and he was found in contempt by COMELEC for occupying the municipal hall and refusing to relinquish office.
On May 14, 1982, Geronimo was forcibly removed from the municipal hall by military personnel, leading to his detention and subsequent habeas corpus petition.

Geronimo's habeas corpus petition argued that his detention was unlawful, claiming COMELEC acted with grave abuse of discretion.
He contended that the contempt resolution was improperly promulgated, that he had received a plurality of votes, and that Pendre lacked standing to file the contempt motion.
The Supreme Court examined the due process requirements in contempt proceedings and found that Geronimo had been adequately notified and given an opportunity to be heard.

The Court ruled that the COMELEC's contempt finding was valid, as Geronimo's actions constituted defiance of a final decision.
The Court acknowledged the political pressures Geronimo faced but maintained that his defiance warranted contempt charges.
However, the Court deemed the five-month imprisonment penalty excessive and ruled that the time already served was sufficient.

In the second petition, Geronimo sought to annul COMELEC's resolution proclaiming Ferrera as mayor, arguing that Ferrera did not receive a plurality of votes.
The Supreme Court agreed, emphasizing that the will of the voters must be respected and that a candidate cannot be declared elected without receiving the majority or plurality of votes.
The Court highlighted that the votes cast for a disqualified candidate should not be treated as stray, especially when there was only one other candidate.

The Court ruled that a permanent vacancy arose in the mayor's office due to Geronimo's disqualification, directing the vice-mayor to assume the position.
The third petition regarding the criminal charges against Geron...continue reading