Case Summary (G.R. No. 199067)
Background of the Petition
The case arose from a petition for certiorari filed by Marcita Mamba Perez to annul the resolutions of the Commission on Elections (COMELEC) regarding the disqualification of Rodolfo E. Aguinaldo from running for the House of Representatives. The petition challenged the May 10, 1998, resolution from the COMELEC that dismissed the disqualification petition and the subsequent denial of a motion for reconsideration on June 11, 1998.
Basis of the Disqualification Petition
Marcita Mamba Perez contended that Aguinaldo did not meet the residency requirement mandated by Article VI, Section 6 of the 1987 Philippine Constitution, which necessitates that a candidate must be a resident of the district for at least one year prior to the elections. She presented evidence showing that, prior to December 1997, Aguinaldo had registered as a voter in Barangay Calaoagan Dackel, Municipality of Gattaran, an area outside the Third District of Cagayan.
Aguinaldo's Defense
In response, Aguinaldo claimed he moved to Tuguegarao in July 1990 and provided supporting documents, including a lease agreement, an affidavit from the apartment owner, and other personal records that indicated his residency in Tuguegarao for more than a year before the elections. He argued that his previous registrations and candidacies did not reflect his true place of residence.
COMELEC's Resolution
The COMELEC unanimously found Aguinaldo qualified to run as representative for the Third District and dismissed Perez’s petition. Following the elections, Aguinaldo won and was proclaimed as the Representative on May 16, 1998.
Jurisdictional Issues
A primary issue addressed was the jurisdiction of the COMELEC after Aguinaldo's proclamation. Aguinaldo asserted that the COMELEC lost jurisdiction over the matter once he took office, while Perez countered that her original petition filed before the elections should allow for continued proceedings.
Legal Framework
Central to the decision was Section 6 of Republic Act No. 6646, which allows for disqualification proceedings to continue even after elections, provided the candidate has not yet been proclaimed. The court ruled that after Aguinaldo's proclamation, the COMELEC had no jurisdiction over the disqualification motion, which also influenced the court’s ability to review the case.
Findings on Eligibility
The Court examined whether Aguinaldo's residency met constitutio
...continue readingCase Syllabus (G.R. No. 199067)
Case Background
- This case involves a petition for certiorari filed by Marcita Mamba Perez against the Commission on Elections (COMELEC) and Rodolfo E. Aguinaldo.
- The petition seeks to annul the resolution dated May 10, 1998, by the First Division of the COMELEC, which dismissed Perez's petition for the disqualification of Aguinaldo as a candidate for Representative of the Third District of Cagayan.
- The COMELEC en banc denied Perez’s motion for reconsideration by resolution dated June 11, 1998.
Facts of the Case
- Rodolfo E. Aguinaldo filed his certificate of candidacy for Representative of the Third District of Cagayan on March 26, 1998.
- Marcita Mamba Perez filed a petition for disqualification on March 30, 1998, claiming Aguinaldo did not meet the residency requirement of one year prior to the elections as mandated by Article VI, Section 6 of the Constitution.
- Evidence presented by Perez included Aguinaldo's certificates of candidacy for governor from 1988 to 1995, voter affidavits, and voter registration records indicating his residency in Barangay Calaoagan Dackel, Gattaran, which is outside the Third District.
- Aguinaldo countered that he moved to Tuguegarao, renting an apartment to conceal his mistress due to his ongoing marriage.
- Aguinaldo presented various documents, including lease contracts and a marriage certificate, to support his claim of residency in Tuguegarao.
COMELEC's Initial Rulings
- On May 10, 1998, the COMELEC's First Division dismissed Perez's disqualification petition, finding Aguinaldo qualified to run for office.
- Aguinaldo was subsequently elected on May 11, 1998,