GR 132774; (June, 1999) (Digest)
G.R. No. 132774 June 21, 1999
RODOLFO E. AGUINALDO, et al., petitioners, vs. COMMISSION ON ELECTIONS, respondent.
FACTS
Petitioners were incumbent provincial and municipal officials in Cagayan. They filed a petition for prohibition to prevent the COMELEC from enforcing Section 67 of the Omnibus Election Code during the 1998 elections. Section 67 states that any elective official running for an office other than their current one (except for President and Vice-President) is considered ipso facto resigned upon filing their certificate of candidacy. Petitioners argued this provision violated the equal protection clause. They contended the classification was invalid, as it unduly favored reelectionists who could use their office’s resources and gave a “special privilege” to presidential and vice-presidential candidates. They also claimed it effectively shortened their constitutionally guaranteed three-year term.
ISSUE
Whether Section 67 of the Omnibus Election Code violates the equal protection clause and the constitutional provision on the term of office of local officials.
RULING
The Supreme Court dismissed the petition. On the equal protection challenge, the Court upheld the reasonableness of the classification. The distinction between an incumbent running for the same office and one running for a different office is based on a substantial difference in intent and commitment. A candidate for a different position demonstrates an intention to relinquish their current post, making the resignation automatic upon candidacy filing a logical consequence. This classification is germane to the law’s purpose of preventing the use of government resources for a new campaign and ensuring serious candidacies. The exception for presidential and vice-presidential candidates was deemed a separate, valid classification considering the national scope and distinct nature of those positions.
Regarding the term of office, the Court ruled that Section 67 does not shorten the constitutional term. The official’s tenure is not curtailed by an external force but is deemed voluntarily terminated by their own act of filing for another office. This constitutes a voluntary renunciation, which the Constitution explicitly states does not interrupt service continuity for term-limit purposes. The Court also noted the petition for prohibition had been rendered moot, as the 1998 elections sought to be enjoined had already been held.