Title
Papandayan, Jr. vs. Commission on Elections
Case
G.R. No. 151891
Decision Date
Nov 18, 2002
A mayoral candidate disqualified by COMELEC won the election; Supreme Court reversed disqualification, annulled proclamation, and ordered rightful proclamation.
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Case Summary (G.R. No. 151891)

Mootness of the Petition

  • The petition has been rendered moot largely due to a prior decision in G.R. No. 147909, which reversed the Commission on Elections (COMELEC) Resolutions that disqualified the petitioner from running for mayor.
  • The void proclamation of the petitioner as the duly elected mayor necessitated the current resolution.

Background of the Election Dispute

  • Mauyag B. Papandayan, Jr. and Fahida P. Balt contested the position of Municipal Mayor of Tubaran, Lanao del Sur in the May 14, 2001 elections.
  • Respondent Balt filed a disqualification case against the petitioner, claiming he was not a resident of Tubaran.
  • The COMELEC ruled on May 8, 2001, declaring the petitioner disqualified and ordered that his votes be considered stray.

Legal Actions Taken by the Petitioner

  • The petitioner filed a motion for reconsideration, which was denied on May 12, 2001.
  • Despite the disqualification, the petitioner received the highest number of votes in the election and subsequently filed a petition for Certiorari with the Supreme Court on May 17, 2001.
  • The petitioner also filed a petition with the COMELEC to count the votes cast in his favor, which was granted with conditions on May 29, 2001.

COMELEC's Orders and Subsequent Developments

  • The COMELEC's May 29, 2001 Order allowed the counting of votes but suspended the petitioner's proclamation pending the resolution of the disqualification case.
  • The Municipal Board of Canvassers proceeded with the proclamation on June 3, 2001, leading to a motion from Balt for annulment, which the COMELEC granted on June 25, 2001.

Legal Basis for COMELEC's Actions

  • The COMELEC cited violations of its own orders and the pendency of the pre-proclamation case as grounds for annulling the petitioner's proclamation.
  • The petitioner filed a motion for reconsideration against the COMELEC's June 25, 2001 Order, which was denied in a subsequent resolution.

Supreme Court's Review and Findings

  • The Supreme Court reviewed the COMELEC's actions and found that the grounds for the suspension and annulment of the petitioner's proclamation were based on the pendency of the disqualification...continue reading

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