Case Summary (G.R. No. 45869)
Applicable Law
The relevant provisions invoked include Article XII(C), Section 10 of the 1987 Philippine Constitution, which prohibits elective public officers from changing their political party affiliation within six months prior to or after an election. This constitutional provision is further supported by Section 4 of Batas Pambansa Blg. 52 and Presidential Decree No. 1661, which outline specific disqualifications for candidates.
Background of the Disqualification
On January 15, 1980, Asuncion and Tuvera filed a petition for Sevilleja's disqualification on grounds of turncoatism, asserting that he had been a member of KBL prior to his candidacy under the NP. An affidavit from Juan Sicam, a KBL official, supported this claim. Sevilleja countered by asserting his continuous affiliation with the NP, asserting he had previously been elected as an NP municipal councilor and barangay captain and maintained active participation in NP activities.
Hearing and Evidence Presentation
A hearing was conducted on January 21, 1980, where both parties presented their respective evidence. The hearing officer received documents from both Sevilleja and the private respondents, with Sevilleja admitting his involvement with KBL while disputing the claims of his disaffiliation from the NP. COMELEC ultimately ruled against Sevilleja, disqualifying him based on his alleged previous affiliation with KBL and subsequently canceling his certificate of candidacy.
Sequence of Events Post-Resolution
Despite the disqualification ruling from COMELEC on January 28, 1980, which Sevilleja claimed was received on January 29, the municipal board proclaimed Perez the winner on February 1, 1980, based on initial counting results. The subsequent destruction of election documents in a fire further complicated the matter, leading to the filing of an election protest by Sevilleja on February 11, 1980, and an additional petition seeking to annul Perez's proclamation.
Petitions Filed by Sevilleja
Sevilleja’s petitions, including G.R. No. 52793 for certiorari and mandamus and G.R. No. 53504 for a review on certiorari regarding the disqualification, were aimed at contesting both the election results and the legality of the disqualification itself. The principal arguments made included alleged grave abuse of discretion by COMELEC in admitting certain pieces of evidence and in concluding that Sevilleja had switched party affiliations.
Judicial Analysis and Findings
The Court examined whether COMELEC had gravely abused its discretion in disqualifying Sevilleja. The Court found that there was ample evidence presented during hearings to substantiate the disqualification claim. The disqualification was based on Sevilleja’s admitted past activities with KBL, along with credible corroborative evidence presented by private respondents that validated the decision made by COMELEC.
Conclusion on Disqualification and Election Outcome
The Court upheld the conclusion that Sevilleja’s actions constituted turncoatism under the cited provisions of the Constitution and associated laws, affirming that the disqualification was justifiable and procedurally correct. Furthermore, the disqualification directly influenced the subsequent election outcomes, as Sevill
...continue readingCase Syllabus (G.R. No. 45869)
Overview of the Case
- The case involves two petitions filed by Felipe M. Sevilleja:
- G.R. No. 52793: An amended petition for certiorari, mandamus, and quo warranto to annul Laureano Perez's proclamation as mayor of San Manuel, Pangasinan.
- G.R. No. 53504: A petition to review the Commission on Elections (COMELEC) Resolutions that canceled Sevilleja's certificate of candidacy.
Background of the Parties
- Petitioner: Felipe M. Sevilleja, the certified Nacionalista Party (NP) candidate for mayor in the January 30, 1980 elections.
- Respondents:
- Laureano Perez, the Kilusang Bagong Lipunan (KBL) candidate for mayor.
- Francisco Asuncion Jr. and Alejandro Tuvera, independent candidates for mayor and vice-mayor, respectively.
Events Leading to the Petitions
- On January 15, 1980, Asuncion and Tuvera filed a petition with COMELEC to disqualify Sevilleja based on allegations of turncoatism, claiming he was a former KBL member.
- Sevilleja denied these allegations, asserting his continuous affiliation with the NP, supported by records of his previous political positions.
Proceedings Before COMELEC
- A hearing on the disqualification petition was conducted on January 21, 1980, where both parties presented evidence.
- On January 28, 1980, COMELEC issued Resolution No. 8532, granting the disqualification and canceling Sevilleja's certificate of candidacy.
Election and Aftermath
- Despite the disqualification, the