Case Summary (G.R. No. 216572)
Election Results and Initial Actions
Following the 2013 elections, Germar and Santos were proclaimed as winners for the mayor and councilor positions, respectively, despite Legaspi's immediate motion to suspend their proclamation due to allegations of rampant vote buying. After the proclamation, which occurred on May 14, 2013, Legaspi submitted a formal Petition for Disqualification against the three candidates, necessitating a review of their conduct during the election.
Proceedings Before COMELEC
The case, designated as SPA No. 13-323 (DC), initially went before the COMELEC First Division, which had an even split decision regarding the validity of the disqualification petition—one commissioner supported it, and one opposed, with an absent member. The division established a Special First Division to move forward, ultimately resulting in a 2-1 vote in favor of disqualifying Germar and Santos for their alleged electoral offenses.
COMELEC En Banc Review and Decision
The petitioners filed motions for reconsideration, but the COMELEC en banc struggled to reach a decisive majority on the electoral aspect of the case. After several votes, the commission eventually found itself equally divided, resulting in the dismissal of the electoral aspect of SPA No. 13-323 (DC) on January 28, 2015. This was executed under Section 6, Rule 18 of the COMELEC Rules of Procedure, citing an inability to reach a majority consensus.
Legal Basis and Ruling
In reviewing the dismissal, the Supreme Court emphasized that, under Section 7 of Article IX-A of the 1987 Constitution, the COMELEC's decisions must be made via a majority vote of all its members. When such a majority fails to materialize, per Section 6 of Rule 18, the action or proceeding should be dismissed if originally commenced in the commission. The Supreme Court clarified that failure to achieve a majority effectively results in the dismissal of the original petition or action, not just the motion for reconsideration.
Interpretation of "Action" and "Proceeding"
Legaspi contended that the COMELEC en banc improperly categorized the case as one that was originally commenced in the commission, which led to an erroneous dismissal. However, the Court clarified that the term "originally commenced in the Commission" encompasses all matters filed before the COMELEC’s divisions, rendering the electoral aspect of SPA No. 13-323 as properly dismissed following the rules of procedure.
Consolidation of Jurisprudence
The Court referenced previous rulings, particularly Mendoza v. COMELEC, which established that failure to achieve a majority vote after rehe
...continue readingCase Syllabus (G.R. No. 216572)
Overview of the Case
- The case involves a Petition for Certiorari filed by Feliciano P. Legaspi against the Commission on Elections (COMELEC) regarding the Order dated January 28, 2015, which dismissed the electoral aspect of his Petition for Disqualification against candidates Alfredo Germar and Rogelio P. Santos, Jr.
- The petition was filed following the May 13, 2013 elections, where Germar won the mayoralty, and Santos won a councilor position in Norzagaray, Bulacan.
The Parties Involved
- Petitioner: Feliciano P. Legaspi, representing the National Unity Party (NUP) and candidate for mayor.
- Respondents:
- Alfredo Germar: Candidate for mayor by the Liberal Party (LP).
- Rogelio P. Santos, Jr.: Candidate for councilor by the LP.
- Roberto C. Esquivel: Candidate for vice-mayor by the LP, who lost the election.
Election Results and Initial Actions
- Germar was declared the highest vote-getter for mayor, with Santos securing enough votes to become the second councilor.
- Legaspi filed a motion to suspend the proclamation of Germar and Santos immediately after the election results were tallied, which was denied by the Municipal Board of Canvassers (MBC).
- The MBC proceeded to proclaim Germar and Santos as duly elected officials on May 14, 2013.
- Following the proclamation, Legaspi filed a Petition for Disqualification before the COMELEC, accusing the respondents of vote-buying.
Proceedings Before the COMELEC
- The Petition for Disqualification, assigned as SPA No. 13-323 (DC), was initially reviewed by the COMELEC First Division,