### Facts:
– **October 16, 1974:** Raul A. Daza obtained lawful permanent residence in the United States, and was issued a green card.
– **June 30, 1987 – June 30, 1992:** Raul Daza served as Congressman for the second Congressional District of Northern Samar.
– **August 12, 1985:** Daza returned to the Philippines, reportedly waiving his permanent resident status in the U.S.
– **February 18, 1992:** Petitioners filed a case for prohibition before the Supreme Court seeking Daza’s disqualification from office, citing his green card holder status, reference to Batas Pambansa Bilang 881 (Omnibus Election Code), Section 68, and the 1987 Constitution, Article XI, Section 18.
– **February 25, 1992:** Supreme Court required the respondents to comment on the petition.
– **March 13, 1992:** Respondents, through the Solicitor General, requested a 30-day extension to file their comment.
– **March 30, 1992:** Petitioners opposed the 30-day extension and requested only 10 days for the respondents to file their comment.
– **April 2, 1992:** Petitioners filed a petition before the COMELEC (SPC 92-084) to disqualify Daza from running in the 1992 elections due to his supposed permanent residency status.
– **April 10, 1992:** Daza filed his comment denying his current status as a permanent resident of the U.S., stating he waived his permanent residency when he returned to the Philippines in 1985.
– **April 13, 1992:** Respondents including Camilo Sabio (Secretary General of the House), Jose Mari Tuaño (OIC, General Services Division), and Rosalia Medina (Chief Accountant), filed their comments. They opined that if Daza was a green card holder, he should be removed from his position.
– **April 17, 1992:** Daza requested the Supreme Court to direct the COMELEC to dismiss SPC No. 92-084, claiming his permanent resident status had ceased.
– **May 21, 1992:** Supreme Court gave due course to the petition and required memoranda from all parties.
– **April 6, 1992:** Petitioners manifested that their intent was to disqualify Daza for the term from June 30, 1987, to June 30, 1992.
### Issues:
1. **Jurisdiction:** Whether the Supreme Court has jurisdiction over the case or whether it belongs to the House Electoral Tribunal.
2. **Mootness:** Whether the case has been rendered moot since Daza’s term ended on June 30, 1992.
3. **Effectiveness of Prohibition:** Whether a writ of prohibition can still be issued given that the term for the office being contested has expired.
4. **De Facto Officer:** Whether Daza, as a de facto officer during his term, should return the emoluments he received and whether his acts are as valid as a de jure officer.
### Court’s Decision:
1. **Jurisdiction:** The Court ruled that jurisdiction over election contests involving members of the House of Representatives resides with the House Electoral Tribunal per Section 17, Article VI of the 1987 Constitution. Hence, the appropriate remedy should have been a petition with the House Electoral Tribunal.
2. **Mootness:** The petition was declared moot and academic as Daza’s term had already ended on June 30, 1992. Thus, there was no longer an existing office from which to restrain him.
3. **Writ of Prohibition:** The Court held that a writ of prohibition, which aims to prevent the execution of acts, could not be issued for acts already consummated. Since Daza’s term expired, any judgment would be ineffectual.
4. **De Facto Officer Doctrine:** The Court ruled that as a de facto officer, Raul Daza’s actions during his term were valid, and he was entitled to compensation for services rendered. The acts of a de facto officer are legally binding as those of a de jure officer.
### Doctrine:
1. **Mootness:** Courts do not render decisions on moot and academic cases, where no actual controversy remains.
2. **De Facto Officer Doctrine:** Acts performed by a de facto officer under the color of authority are valid as if executed by a de jure officer. A de facto officer is entitled to compensation for their service.
### Class Notes:
– **Quo Warranto:** Challenges regarding the eligibility or disqualification of an elected official must be filed within ten days after proclamation. (Revised Rules of the House Electoral Tribunal).
– **De Facto Officer:** Acts performed and emoluments received by de facto officers are considered legal and valid. (Martin, Administrative Law).
– **Moot and Academic:** Courts will not decide cases if the issue has become moot, i.e., if no live controversy exists or if intervening events have rendered judicial determination irrelevant.
### Historical Background:
The case unfolded against the backdrop of heightened scrutiny of the qualifications of public officials under the 1987 Philippine Constitution. The petitioners emphasized adherence to laws preventing dual allegiances, reflecting concerns over national integrity and the allegiance of public officials. This case reaffirmed procedural proper channels for contesting electoral qualifications, entrusting the House Electoral Tribunal with such jurisdiction.
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