Case Summary (G.R. No. 127318)
Background of the Case
In the May 6, 1996 SK elections, Marquez was elected SK Chairman of Barangay Putatan, Muntinlupa City. Liberty Santos, who lost to Marquez, initiated an election protest on May 16, 1996, alleging Marquez’s disqualification due to age. The MeTC issued a Temporary Restraining Order preventing Marquez from taking his oath of office. In response, Marquez filed a motion to dismiss the protest, asserting that the trial court lacked jurisdiction and that the matter fell under the jurisdiction of the city/municipal Election Officer as stipulated in Section 6 of COMELEC Resolution No. 2824.
Arguments Presented
Marquez argued that the legitimacy of his election should be resolved by the Election Officer, as cases concerning eligibility are determined prior to elections, and that the MeTC had no authority to adjudicate such matters post-election. Conversely, Santos argued for a broader interpretation of "election protest," contending that it encompasses disqualification issues even after an election, particularly due to the failure of the Election Officer to act on the matter.
Resolution by Lower Courts
On June 4, 1996, the MeTC denied Marquez's motion to dismiss, asserting its jurisdiction over the disqualification case under the principle of exhaustion of administrative remedies. The court interpreted the relevant provisions of COMELEC Resolution No. 2824 to allow for disqualification proceedings after an election has concluded.
Petition for Certiorari and Prohibition
Marquez filed a petition for certiorari and prohibition with the COMELEC, claiming the MeTC's resolution misapplied the law regarding its jurisdiction. He reiterated that Section 6 of COMELEC Resolution No. 2824 should govern in determining the eligibility of candidates, while the respondents maintained that the MeTC had the authority under Section 253 of the Omnibus Election Code to hear disqualification cases.
Jurisdictional Analysis
The COMELEC upheld the MeTC's jurisdiction, reasoning that the proceedings initiated after the election pertained to disqualification matters and thus fell under the court's purview. It emphasized that cases concerning the eligibility of candidates
...continue readingCase Syllabus (G.R. No. 127318)
Introduction to the Case
- This case involves a Petition for Certiorari and Prohibition filed by Francis King L. Marquez against the Hon. Commission on Elections (COMELEC), Hon. Noli C. Diaz (Presiding Judge, Metropolitan Trial Court, Branch 80, Muntinlupa City), and Liberty Santos.
- The petition challenges the COMELEC's Resolution dated November 19, 1996, which affirmed the jurisdiction of the Metropolitan Trial Court to hear a disqualification case based on age against Marquez.
Background of the Case
- Francis King L. Marquez and Liberty Santos were candidates for the position of Sangguniang Kabataan (SK) Chairman in Barangay Putatan, Muntinlupa City during the May 6, 1996 elections.
- Marquez was proclaimed the SK Chairman after receiving the highest number of votes on the election day.
- Following this, Santos filed an election protest with the Metropolitan Trial Court, claiming Marquez's disqualification due to age.
Proceedings in the Metropolitan Trial Court
- The trial court found the election protest sufficient in form and substance and issued a Temporary Restraining Order preventing Marquez from taking his oath of office.
- Marquez filed a Motion to Dismiss the election protest, arguing that the case should be treated as a quo warranto proceeding and that the Metropolitan Trial Court lacked jurisdiction over the matter.
Arguments of the Parties
Petitioner's Argument (Francis King L. Marquez):
- Claimed that the trial court's jurisdiction was limited to issues of fraud and irregularities in the conduct of the SK elections, as outlined in COMELEC Resolution No. 2824.
- Asserted that eligibility issues sh