Jurilla v. Commission on Elections
NEW DOCTRINEFacts
1. The Antecedents: Petitioners Eugenio Jurilla, Marciano Medalla, Bernardo Nazal, Rey Medina, Melencio Castelo, and Godofredo Liban were candidates for councilor in the Second District of Quezon City in the May 11, 1992 synchronized elections. Respondent Antonio V. Hernandez also filed a certificate of candidacy for one of the six councilor positions in the same district. The core of the dispute revolves around Hernandez's qualifications, specifically his residency and voter registration, as indicated in his certificate of candidacy and accompanying biodata, which petitioners alleged were deficient and did not clearly establish his eligibility to run for office in the Second District of Quezon City. 2. Procedural History: Petitioners filed a petition for disqualification against respondent Antonio V. Hernandez with the Commission on Elections (COMELEC) after becoming aware of alleged deficiencies in his certificate of candidacy. They contended that Hernandez's certificate and biodata did not explicitly state he was a registered voter of Quezon City or a resident of the Second District, as required by law. COMELEC, however, issued a resolution on June 2, 1992, denying the petition for disqualification, deeming it filed outside the reglementary period applicable to nuisance candidates under Section 5 of RA 6646. This resolution was based on COMELEC's interpretation that the petition was essentially one to declare Hernandez a nuisance candidate, a classification the Supreme Court later found erroneous. 3. The Petition: The petitioners filed the instant petition for certiorari before the Supreme Court, alleging that COMELEC committed grave abuse of discretion amounting to lack of jurisdiction in issuing its resolution of June 2, 1992. They argued that COMELEC erred in treating their petition as one for a nuisance candidate and in dismissing it based on a reglementary period that did not apply. The petitioners sought to have COMELEC's resolution nullified, asserting that Hernandez was not qualified to run for councilor in the Second District of Quezon City due to the alleged deficiencies in his certificate of candidacy and voter registration status.
Issue(s)
Whether the COMELEC committed grave abuse of discretion in denying the petition for disqualification on the ground that it was filed out of time. Whether respondent Antonio V. Hernandez was qualified to run for Councilor in the Second District of Quezon City.
Ruling
The petition is dismissed. The Supreme Court sustained the COMELEC's conclusion to dismiss the petition and give due course to the candidacy of respondent Hernandez, finding him to be a qualified voter of Precinct No. 233-B, New Capitol Estates, Barangay Batasan Hills.
Ratio Decidendi
On the issue of the COMELEC's ruling on the timeliness of the petition: The Court found that the COMELEC erred in treating the petition as one concerning a "nuisance candidate" under Section 69 of BP Blg. 881. The grounds for disqualification raised by the petitioners did not fall under the definition of a nuisance candidate, as there was no indication that Hernandez filed his certificate of candidacy to mock the election process or cause confusion. Consequently, the procedural period for nuisance candidates under Section 5 of RA 6646 and Rule 25 of the COMELEC Rules of Procedure were not properly invoked by the COMELEC in dismissing the petition. On the issue of respondent Hernandez's qualification: The Court held that Section 39(a) of the Local Government Code of 1991 does not specifically require a candidate to state his precinct number and barangay of registration in his certificate of candidacy. It is sufficient that the candidate is actually registered as a voter in a precinct within the district where he intends to be elected. The failure of Hernandez to state his precinct number in his certificate of candidacy was satisfactorily explained by him, and it was judicially confirmed by the Metropolitan Trial Court of Quezon City that he was a registered voter of Precinct No. 233-B, New Capitol Estates, within the Second District of Quezon City. This judicial confirmation established his eligibility and qualification to run for the position. The Court noted that Hernandez had been a resident of the Second District for two years prior to the elections and had previously been a registered voter of Manila. The MTC's order to include him in the registry of voters, granted without opposition, served as definitive proof of his status as a qualified voter in the said precinct and district. Therefore, the COMELEC's conclusion to give due course to his candidacy, despite its erroneous premise regarding nuisance candidates, was sustained based on his established qualification.
Main Doctrine
A candidate's failure to state his precinct number in his certificate of candidacy is not fatal if it is satisfactorily explained and judicially confirmed that he is a registered voter within the district where he intends to be elected, and that he possesses all the qualifications and none of the disqualifications for the office.