G.R. No. 88831. November 08, 1990 (Case Brief / Digest)

### Title:
**Mateo Caasi vs. The Hon. Court of Appeals and Merito C. Miguel: A Case of Electoral Disqualification Based on Green Card Holder Status**

### Facts:
Two consolidated cases – G.R. No. 84508 and G.R. No. 88831 – sought the disqualification of Merito C. Miguel from holding the elected position of municipal mayor of Bolinao, Pangasinan. The grounds for disqualification revolved around Miguel’s status as a green card holder, implying permanent residency in the United States rather than the Philippines. Various petitions and motions filed across different legal venues, including the Commission on Elections (COMELEC) and the Court of Appeals, contested Miguel’s eligibility based on these residency concerns. Despite Miguel’s counter-claims that his green card was merely for convenience, the legal journey highlighted serious questions about the implications of his U.S. residency on his eligibility for public office in the Philippines.

### Issues:
1. Whether a green card constitutes proof of permanent residency in the United States.
2. Whether respondent Miguel waived his status as a permanent resident of the United States prior to the local elections.

### Court’s Decision:
The Supreme Court invalidated Miguel’s election as mayor, establishing that:
– Possession of a green card indeed serves as proof of U.S. permanent residency.
– Miguel failed to demonstrate a clear waiver of his U.S. permanent residency status prior to his candidacy, rendering him disqualified under Section 68 of the Omnibus Election Code.

### Doctrine:
The case reaffirmed the principle that Philippine citizens holding permanent residency in a foreign country, specifically through possession of a green card, are disqualified from running for any elective public office unless they unequivocally waive such foreign residency status in compliance with Philippine election laws.

### Class Notes:
1. **Legal Statutes:** Section 68 of the Omnibus Election Code and Section 18, Article XI of the 1987 Constitution are pivotal in understanding the disqualification grounds related to foreign residency.
2. **Principle of Exclusion:** Philippine citizens with dual loyalties, evidenced by permanent residency status in a foreign country, are excluded from elective public office candidacy to ensure undivided allegiance to the Philippines.
3. **Waiver Requirement:** A candidate’s waiver of foreign residency status must be explicit and precede the filing of candidacy, not presumed from the act of candidacy itself.
4. **Residency Qualifications for Candidates:** At least one-year residency in the area of intended office prior to candidacy; by holding U.S. permanent residency, a candidate fails to meet this requirement.
5. **Doctrine of Clear Evidence:** Clear proof of waiver of foreign residency status is essential; speculative or implied waivers are insufficient for candidacy eligibility.

### Historical Background:
This case spotlighted the broader issue of allegiance and eligibility for public office in the wake of rumors that several officials in the administration then held green cards. By addressing Miguel’s case, the Supreme Court set a precedent on how dual residency and allegiance concerns are treated vis-à-vis eligibility for public office, reflecting on the integrity and full allegiance required from elected officials to the Philippine Constitution and its citizens.


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