Case Summary (G.R. No. L-28613)
Applicable Law
Legal provisions relevant to this case include the Revised Penal Code, which outlines disqualifications resulting from a criminal conviction, and the Revised Administrative Code, which delineates voter eligibility requirements. The Supreme Court evaluates the intersection of these laws regarding the impact of a presidential pardon on Abes's eligibility.
Background of the Case
After being convicted and serving part of his sentence, Abes applied for voter registration but was denied. He nonetheless filed a certificate of candidacy for the mayor’s office and was subsequently elected. Lacuna, finishing second in the election, filed a petition for quo warranto against Abes, arguing that Abes was ineligible to run for mayor because he was not a qualified voter at the time of the election, citing the disqualifications from his previous conviction.
Arguments of the Parties
Lacuna contends that Abes's conviction prohibited him from being a qualified voter during the election, maintaining that the presidential pardon did not retroactively restore his disqualifications. Conversely, Abes argues that he was otherwise qualified despite his non-registration and that the pardon effectively erased the disqualifications stemming from his conviction, enabling him to hold public office.
Court's Findings on Disqualifications
The lower court recognized that while Abes faced a temporary absolute disqualification during the term of his sentence, the perpetual special disqualification from suffrage remained in effect beyond the expiration of his prison term. Therefore, at the time of the election, Abes was indeed disqualified from voting or holding public office. However, the pivotal legal question arose regarding whether the presidential pardon rectified his disqualifications, particularly those that were perpetual in nature.
Effect of Presidential Pardon
The court examined the implications of the absolute pardon issued to Abes. Citing previous rulings, the court underscored the constitutional prerogative of the President to grant pardons, which historically have been interpreted to eliminate the consequences of conviction, including disqualifications for public office. Emphasizing a broader interpretation, the court held that the timing of Abes's par
...continue readingCase Syllabus (G.R. No. L-28613)
Case Overview
- This case involves an appeal from a dismissal of a petition for quo warranto challenging the eligibility of Benjamin H. Abes, who was elected mayor of Peñaranda, Nueva Ecija, in the elections held on November 14, 1967.
- The petitioner-appellant, Ambrocio Lacuna, contested Abes's eligibility based on his prior conviction and the subsequent denial of his voter registration.
Factual Background
- Benjamin H. Abes was convicted of counterfeiting treasury warrants and sentenced to an indeterminate penalty of six years and one day to eight years, eight months, and one day of prision mayor, along with a fine of five thousand pesos (P5,000.00).
- Abes was granted a conditional pardon on April 7, 1959, remitting only the unexpired portion of his sentence and fine.
- Following his conviction, Abes applied for voter registration for the upcoming elections but was denied. Despite this, he filed his certificate of candidacy and won the election.
Procedural History
- On November 16, 1967, the municipal board of canvassers proclaimed Abes as duly elected mayor.
- Lacuna, who placed second in the elections, filed a petition for quo warranto with an application for a preliminary injunction on November 23, 1967.
- On December 7, 1967, while the case was pending, Abes was granted an absolute and unconditional pardon by the President of the Philippines, restor