Title
Mayor vs. Villacete
Case
G.R. No. L-16190
Decision Date
May 31, 1961
Voters in San Agustin, Romblon, challenged their exclusion from voter lists over citizenship claims. Post-election, Supreme Court deemed petitions moot, allowing future citizenship claims.
exclusion case
citizenship
permanent list of voters

Case Summary (G.R. No. L-16190)

Petitions and Procedural History

After the petitions were elevated to the court of first instance, the trial court set the exclusion cases for hearing on November 4, 1959. On that date, petitioners filed a motion to dismiss. They argued, among others, that the trial court had no jurisdiction to entertain the exclusion petitions because the ground relied upon was the citizenship of petitioners, which they claimed could not be inquired into in an exclusion case, and that this ground did not fall within the coverage of Section 121, in relation to Section 123, of the Revised Election Code.

The trial court denied the motion. Petitioners then manifested their intention to press the issue before the Supreme Court by filing a special civil action for prohibition with preliminary injunction, and requested that the hearing of the exclusion cases be postponed pending the Supreme Court’s disposition. The trial court did not accede to the request, citing lack of time and the urgent nature of the exclusion proceedings.

One petitioner, Lucio L. Mayor, was a candidate for mayor and had a duly registered certificate of candidacy. Because of his position as an official candidate affected by the exclusion ruling, he filed a petition for prohibition before the Supreme Court on November 6, 1959, docketed as G.R. No. L-16190. The Supreme Court gave due course on November 9, 1959 via resolution. In the interim, Mayor requested by telegraphic wire that the trial court defer the hearing of the exclusion case affecting him. Despite that request, on November 7, 1959, the trial court proceeded to hear all exclusion cases affecting petitioners, including that of Mayor, and rendered a decision holding that the petitioners were not Filipino citizens and were thus disqualified to vote in the ensuing elections.

The elections were held on November 10, 1959. On December 11, 1959, petitioners filed the present petition for certiorari, alleging grave abuse of discretion amounting to lack of jurisdiction by the trial court. Because of the interrelation of the two cases, the Supreme Court consolidated them.

Issues Raised by Petitioners

Petitioners’ principal theory was that the trial court lacked jurisdiction in the exclusion cases because the basis for exclusion was petitioners’ alleged citizenship, which petitioners maintained could not be inquired into in an exclusion case. They further contended that the ground invoked did not come within the scope of Section 121, in relation to Section 123, of the Revised Election Code. In substance, the petition challenged the trial court’s authority to determine citizenship in an exclusion proceeding, and thus its authority to disqualify petitioners from voting in the elections held shortly thereafter.

The Parties’ Position on Jurisdiction and Remedy

Petitioners treated their certiorari petition as the only legal remedy that could bring to the Supreme Court the jurisdictional issue. They alleged that the trial court’s action amounted to grave abuse of discretion that rose to the level of lack of jurisdiction. They also relied on the special and urgent nature of election-related exclusion proceedings to justify their resort to immediate Supreme Court relief.

Mootness and the Effect of the Elections

The Court held that both petitions had become moot. It reasoned that once the elections were held on November 10, 1959, the purpose for which the petitions had been filed had become functus oficio. The Court emphasized that the petitions had been filed to prevent the trial court from acting on the exclusion cases on the asserted ground of lack of jurisdiction, so that if the petitions succeeded, petitioners’ names would remain in the permanent list of voters and they could vote in the elections scheduled for November 10, 1959.

Because the elections had already taken place, the Court ruled that the petitions’ objective had become purposeless. While it acknowledged that the decision of a court of first instance in an exclusion case was final and unappealable, the Court still held that the petition did not serve any useful purpose at that stage because the petitioners’ main objective was to dispute the trial court’s action as it related to the elections already concluded.

Nature of Exclusion Decisions and Availability of Future Relief

The Court also addressed the effect of an exclusion-case decision. It held that, considering the summary character of an exclusion case, the decision rendered by a court of first instance—although final and unappealable—did not acquire the nature of res judicata. The Court cited Nuval vs. Guray, 52 Phil., 645 for the proposition that an exclusion-case decisio

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