**Facts:**
1. **Initial Filing and Claim:** On October 3, 2012, John Henry R. Osmeña filed his Certificate of Candidacy (COC) for mayor of Toledo City, Cebu, claiming 15 years of residency prior to the May 2013 elections.
2. **Petitioners’ Challenge:** Lina Dela Peña Jalover, Georgie A. Huso, and Velvet Barquin Zamora filed a petition with COMELEC to cancel Osmeña’s COC, alleging material misrepresentation and failure to meet residency requirements. They claimed:
– Osmeña did not own property in Toledo City.
– His declared residence was dilapidated and owned by his son.
– He had no business permits in Toledo City.
– Affidavits from residents claimed he was rarely seen in Toledo City.
3. **Osmeña’s Defense:** Osmeña countered with:
– Evidence of ties to Toledo City dating back to 1995, including real estate purchases and voter registration.
– Certificates and documents proving residency and local activities.
– Affidavits asserting his significant socio-political involvement in the city.
4. **COMELEC Second Division Ruling:** COMELEC dismissed the petition, supporting Osmeña’s consistent residency ties since at least 2006 and no material misrepresentation.
5. **Motion for Reconsideration:** Petitioners filed for reconsideration, which COMELEC en banc also denied, reinforcing that ownership of a house was not a mandatory qualification and residency could be established through other means like rented properties or relatives’ homes.
6. **Proceedings to the Supreme Court:** Petitioners argued that:
– Osmeña’s alleged residency was a falsification of material fact.
– Awarding Osmeña the mayoral seat despite residency discrepancies undermines democratic principles.
– COMELEC displayed bias by accepting late submissions from Osmeña.
**Issues:**
1. Whether the COMELEC acted with grave abuse of discretion in determining Osmeña’s eligibility based on residency.
2. Whether Osmeña misrepresented material facts regarding his residency in his COC.
3. Whether there was partiality in COMELEC’s procedural decisions favoring Osmeña.
**Court’s Decision:**
1. **Limited Jurisdiction in Certiorari Petitions:** The Supreme Court emphasized restrictions in disturbing factual findings of COMELEC unless a gross misuse of jurisdiction or grave abuse of discretion is apparent.
2. **Residency Requirement Compliance:**
– **Substantial Evidence:** The Court, applying substantial evidence standard, found Osmeña sufficiently proved residency through consistent ties since 2006, electoral participation, and physical presence.
– **Legal Interpretation of Residency:** The non-necessity of property ownership for residency affirmation was endorsed, considering leases or residence with relatives sufficient.
3. **Material Misrepresentation Analysis:**
– **Intent and Significance:** The Court found no deliberate intent by Osmeña to mislead or deceive regarding his qualifications and residency declaration on the COC.
– **Cases Cited for Reference:** Velasco v. COMELEC and Mitra v. COMELEC reiterated non-ownership not impeding residency claims and upheld the standard for determining domicile of choice.
4. **Procedural Fairness:** The Court dismissed allegations of partiality, noting procedural errors claimed by the petitioners lacked substantiation and supporting evidence.
5. **Doctrine:**
– **Residency Definition:** Establishing domicile requires both physical presence and the intention to remain. Ownership of a property isn’t necessary; residency can be through rental or residing with family.
– **Substantial Evidence Standard:** Upheld for assertions of fact in election-related petitions.
– **Material Misrepresentation:** Requires deliberate intent to mislead voters regarding essential qualification criteria.
**Class Notes:**
– **Key Elements in Election Cases:** Residency requirements, material misrepresentation in COCs, substantial evidence review, electronic Code – Sections 74 and 78.
– **Legal Statutes:**
– **1987 Constitution**: Article X, Section 3 – Local Government Code.
– **Local Government Code of 1991**: Section 39 – Qualifications of local elective officials.
– **Omnibus Election Code**: Sections 74 and 78 – COC content and falsity grounds.
**Historical Background:**
This case is contextualized within election law, focusing on preventing unfamiliar candidates from influencing local elections. It underscores the robust democracy principle, maintenance of candidacy integrity, and the regulatory framework ensuring qualified representations in local governance, addressing foundational concerns dating back to early 20th-century Philippine electoral laws.
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