G. R. No. 31624 - Antonio G. Jayme et al. vs. The Bacolod-Murcia Milling Co., Inc. ~Philippine National Bank vs. Antonio G. Jayme et al. ~Philippine National Bank vs. Antonio G. Jayme ~Antonio Jayme y Ledesma vs. Philippine National Bank et al. ~Philippine National Bank vs. Antonio G. Jayme et al.

Case Summary (G. R. No. 31624)

Procedural History and Relief Awarded Below

The Court of First Instance held (a) Monroy ceased to be mayor upon filing his certificate on September 15, 1961; (b) del Rosario became mayor upon assuming office on September 21, 1961; (c) Monroy was liable to reimburse del Rosario the actual salaries to which del Rosario was entitled as mayor from September 21, 1961, until Monroy could reassume the office; and (d) Monroy was to pay P1,000.00 as moral damages. On appeal, the Court of Appeals affirmed the trial court in all respects except that it eliminated the award of moral damages. Petitioner then sought certiorari review before the Supreme Court.

Jurisdictional Issue: Whether Courts Could Review a COMELEC Resolution

Petitioner argued the lower courts lacked jurisdiction to review COMELEC’s resolution approving the withdrawal. The Supreme Court rejected this contention. The Court explained that while the Constitution empowers COMELEC to decide administrative questions affecting elections and generally makes its decisions reviewable only by the Supreme Court, that jurisdiction is limited to matters connected with the “conduct of elections.” In the present case there was no controversy before COMELEC: respondent never contested the filing or the withdrawal before that body. Moreover, the legal question presented—whether Monroy remained mayor after filing a certificate of candidacy—was purely a legal dispute unconnected to the mechanics of conducting the election. Because the disputed issue did not affect the conduct of the electoral process, it properly fell within the cognizance of the courts rather than as an administrative election question for COMELEC.

Legal Effect of Filing a Certificate of Candidacy under Sec. 27

The Court affirmed that Section 27 of the Revised Election Code makes the forfeiture of the incumbent’s office automatic and effective from the very moment the certificate of candidacy for another office is filed. The statute contemplates a permanent forfeiture upon filing; subsequent events, including a later withdrawal of the certificate, do not retroactively alter that forfeiture. The Court cited Castro v. Gatuslao for the principle that the law makes the vacating effective as of the moment of filing and does not make forfeiture contingent on future happenings.

Validity of the Withdrawal and the Question of Consent

The Court addressed petitioner’s contention that the certificate had been filed without his knowledge or consent and that the COMELEC’s approval of withdrawal therefore voided the certificate ab initio. The Court found that (a) the COMELEC resolution did not expressly invalidate the certificate; (b) a withdrawal does not necessarily render the original filing void of its legal effects, since the filing already produced permanent legal consequences; and (c) both the trial court and the Court of Appeals expressly found as a fact that the certificate was filed with petitioner’s knowledge and consent. Given that the remedy invoked before the Supreme Court raised principally legal questions, that factual finding was treated as conceded for purposes of the present review.

Compensation and the De Facto Officer Doctrine

Petitioner relied on Rodriguez v. Tan, where a proclaimed senator who was later ousted in an election contest was allowed to retain emoluments received during his incumbency. The Supreme Court distinguished Rodriguez as factually and legally dissimilar: Rodriguez involved a proclaimed elective official assumed under a contested election result and thus implicated discrete equitable considerations. In contrast, the present controversy concerned forfeiture of office by operation of law under Section 27 and the filling of the vacancy by the vice‑mayor. The Court applied the

Case Syllabus (G. R. No. 31624)

Procedural History

Petition for certiorari filed with the Supreme Court to review the decision of the Court of Appeals affirming the judgment of the Court of First Instance of Rizal, sitting in Pasig.
Original action: suit for injunction and quo warranto instituted by petitioner Roberto R. Monroy against respondents (Hon. Court of Appeals and Felipe Del Rosario).
Trial Court (Court of First Instance of Rizal) held: (a) petitioner ceased to be Mayor of Navotas after filing his certificate of candidacy on September 15, 1961; (b) respondent del Rosario became municipal mayor upon assuming office on September 21, 1961; (c) petitioner must reimburse actual damages in the form of salaries to which respondent was entitled as Mayor from September 21, 1961 until petitioner could reassume office; and (d) petitioner must pay respondent P1,000.00 as moral damages.
Court of Appeals affirmed the trial court’s judgment in toto except that it eliminated the award of moral damages; it reaffirmed its position on reconsideration.
Petitioner sought review in the Supreme Court by certiorari.

Facts

Roberto Monroy was incumbent Mayor of Navotas, Rizal.
On September 15, 1961, Monroy’s certificate of candidacy as representative of the first district of Rizal for the forthcoming elections was filed with the Commission on Elections (Comelec).
On September 18, 1961, Monroy filed a letter withdrawing that certificate of candidacy.
The Commission on Elections, by resolution, approved the withdrawal. (The record does not include a copy of the resolution; it does not appear when this resolution was issued.)
On September 21, 1961, Felipe del Rosario, then Vice-Mayor of Navotas, took his oath of office as Municipal Mayor on the theory that Monroy had forfeited the mayoralty upon filing the certificate of candidacy.
Trial court and Court of Appeals found as fact that the certificate in question was filed with petitioner’s knowledge and consent.

Issues Presented

Whether the lower courts exceeded their jurisdiction by reviewing a resolution of the Commission on Elections.
Whether filing a certificate of candidacy operates as an automatic and permanent forfeiture of the elective office then held under Sec. 27 of the Revised Election Code.
Whether withdrawal of the certificate of candidacy and the Comelec’s approval of such withdrawal restored petitioner to his former office.
Whether petitioner was liable to reimburse respondent del Rosario for salaries received as mayor from September 21, 1961 until petitioner could reassume the office.
Whether moral damages awarded by the trial court should be sustained.

Jurisdictional and Reviewability Analysis Regarding the Commission on Elections

The Constitution empowers the Commission on Elections to decide, save those involving the right to vote, all administrative questions affecting elections, and the Commission’s decisions, orders and rulings on such administrative questions are reviewable only by the Supreme Court. (Philippine Constitution, Art. X, sec. 2; see also Sec. 5, Rev. Election Code.)
The powers of the Commission are limited to matters connected with the "conduct of elections"; consequently, its adjudicatory or quasi-judicial powers are likewise limited to controversies connected with the conduct of elections.
The phrase "conduct of elections" includes the administrative processes of preparing and operating the election machinery so the people may exercise their right to vote; all questions arising therefrom are for exclusive resolution by the Commission, subject to Supreme Court review. (See Guevara v. Commission on Elections, L-12596, July 31, 1958.)
In this case, there was no decision, order or ruling of the Commission on any administrative question or controversy: respondent never contested the filing of the certificate before the Commission nor disputed the withdrawal before that body.
Even if there had been a controversy before the Commission, it could not have related to the conduct of the elections here: the parties contested a purely legal question—whether petitioner remained municipal mayor after September 15, 1961—which has no bearing on the conduct of the congressional election.
The Commission’s only interest is to know who the candidates are for the forthcoming elections; when petitioner withdrew his certificate, as far as the Commission could be concerned he was no longer a candidate.
Therefore the purely