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**Facts:**
Rogelio Batin Caballero, a candidate for the mayoral position in Uyugan, Batanes, faced opposition from Jonathan Enrique V. Nanud, Jr., who challenged Caballero’s eligibility based on citizenship and residency. Nanud’s petition alleged that Caballero made false representations in his Certificate of Candidacy (COC) by stating he was eligible to run, despite being a Canadian and a non-resident of Uyugan.
– **October 1, 2012:** Caballero renounced his Canadian citizenship.
– **October 3, 2012:** Caballero filed his COC.
– **May 3, 2013:** COMELEC First Division canceled Caballero’s COC, citing misrepresentation in his residency claim.
– **May 14, 2013:** Despite the cancellation, Caballero was proclaimed the winner of the mayoral election.
– **May 16, 2013:** Caballero filed a motion for reconsideration.
– **May 17, 2013:** Nanud filed a Petition to Annul Proclamation.
– **November 6, 2013:** COMELEC En Banc denied Caballero’s motion for reconsideration.
– **December 12, 2013:** COMELEC issued a writ of execution pronouncing Nanud as the duly-elected Mayor after Caballero’s COC was voided.
– **December 20, 2013:** Nanud took his oath of office.
– **Caballero petitioned to the Supreme Court seeking annulment of COMELEC decisions, arguing procedural irregularities and incorrect findings on his residency status.**
**Issues:**
1. Whether COMELEC erred in liberally applying procedural rules that led to acceptance of Nanud’s petition.
2. Whether Caballero abandoned his Philippine domicile upon becoming a Canadian citizen and if so, whether his reacquisition of Philippine citizenship and nine-month stay in Uyugan sufficed for the one-year residency requirement.
3. Whether Caballero made a material misrepresentation in his COC regarding his residency.
**Court’s Decision:**
**1. COMELEC’s Liberal Application of Rules:**
The Supreme Court upheld the COMELEC’s decision, affirming its discretion to liberally interpret procedural rules under Section 4, Rule 1 of their Rules of Procedure. The interest of public justice justified the acceptance of Nanud’s petition despite procedural lapses.
**2. Abandonment of Domicile and Residency Requirement:**
The court agreed with COMELEC that Caballero had abandoned his Philippine domicile by becoming a Canadian citizen. His reacquisition of Philippine citizenship under RA 9225 did not automatically restore his domicile in Uyugan. Since residency in Uyugan only counted from September 13, 2012, Caballero could not meet the one-year residency requirement by the election day on May 13, 2013.
**3. Material Misrepresentation in COC:**
Caballero’s assertion of one-year residency in Uyugan was materially false. The court reaffirmed that a false representation related to a material fact, such as residency, justified the cancellation of Caballero’s COC under Section 78 of the Omnibus Election Code.
**Doctrine:**
**1. Liberal Construction of Procedural Rules:** COMELEC rules are subject to liberal interpretation to ensure justice and the integrity of elections.
**2. Reacquisition of Filipino Citizenship and Residency:** RA 9225 allows dual nationality but does not affect residency unless sufficient proof of reestablished domicile is provided as required for local elective positions under the Local Government Code.
**3. Material Misrepresentation:** Falsely declaring qualifications like residency in a COC constitutes material misrepresentation, warranting cancellation under the Omnibus Election Code.
**Class Notes:**
**Key Concepts:**
1. **Domicile and Residency:** Understanding that citizenship and domicile are distinct legal concepts. Citizenship defines legal nationality, while domicile determines a person’s permanent home for legal purposes.
2. **Material Misrepresentation:** False statements in COC regarding qualifications essential for the election, such as residency, are grounds for disqualification.
3. **Procedural Rules in Election Cases:** COMELEC’s discretion to prioritize substantive justice over procedural technicalities emphasizes public interest in electoral disputes.
**Statutory Provisions:**
– **Republic Act 9225, Section 5(2):** Conditions for reacquiring Philippine citizenship and qualifications for running for public office.
– **Local Government Code, Section 39:** Qualifications for local elective officials, emphasizing the requisite one-year residency for eligibility.
– **Omnibus Election Code, Section 78:** Grounds for canceling a COC based on false material representation.
**Historical Background:**
The case arose in the context of the 2013 local elections in the Philippines, underscoring issues of dual citizenship and electoral qualifications as global migration patterns increasingly lead to dual nationalities and complex legal scenarios around political eligibility.
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