Case Summary (G.R. No. 100912)
Relevant Facts Surrounding the Candidacy
On March 23, 1992, Antonio V. Hernandez submitted his certificate of candidacy to the Commission on Elections (COMELEC) for one of the contested councilor positions. In his application, he specified his address as "B 26, L 1 New Capitol Estates, Quezon City," but failed to include his Precinct Number and Barangay details, which raised questions about his qualifications. Contradictorily, his submitted biodata indicated that his address was "Acacia Street, Mariana, Quezon City," which fell within the Fourth District, complicating his eligibility under the provisions of Section 39, paragraph (a) of the Local Government Code of 1991.
Legal Challenges to Hernandez’s Candidacy
The petitioners contested Hernandez's qualifications post-election, asserting that they discovered the grounds for disqualification only after the elections. They invoked Rule 25 of the COMELEC Rules of Procedure, allowing for petitions to be filed after the last day for candidacy submissions, but before the date of proclamation. However, on June 2, 1992, the COMELEC denied the petition, stating it was filed outside the regulatory period established by Section 5 of Republic Act No. 6646, pertaining to nuisance candidates.
Evaluation of Candidate's Address and Voter Registration
Despite the challenges, the case revealed that Hernandez had not been assigned a Precinct Number at the time of his candidacy submission, as he had only recently transitioned from being a registered voter in Manila to residing in Quezon City. He testified that he had resided at his stated address for two years and that his failure to register in time was due to illness. The Barangay Captain corroborated this residency claim, further supporting Hernandez’s qualifications as a voter.
Judicial Acknowledgment of Voter Registration
The Metropolitan Trial Court of Quezon City examined Hernandez’s petition for inclusion on the list of registered voters, ultimately ruling in his favor and confirming his eligibility to vote in the subsequent elections. There was no opposition to his petition during the hearing, leading to a formal order directing the inclusion of Hernandez's name in the vote
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Case Background
- This case involves the petitioners Eugenio Jurilla, Marciano Medalla, Bernardo Nazal, Rey Medina, Melencio Castelo, and Godofredo Liban, who were candidates in the synchronized elections held on May 11, 1992, for six councilor positions in the Second District of Quezon City.
- Respondent Antonio V. Hernandez filed his certificate of candidacy on March 23, 1992, but failed to provide his Precinct Number and specific Barangay of registration on the document.
Issues of Candidate Eligibility
- Hernandez's biodata indicated his address as Acacia Street, Mariana, Quezon City, which belongs to the Fourth District, raising questions about his residency in the Second District where he was running.
- The petitioners contended that Hernandez's failure to indicate his Precinct Number and Barangay in his certificate of candidacy rendered him unqualified under Section 39, paragraph (a) of the Local Government Code of 1991, which sets qualifications for elective local officials.
Proceedings and COMELEC's Resolution
- The petitioners challenged Hernandez's qualifications before the Commission on Elections (COMELEC) but filed the petition afte