GR 136351 Romero (Digest)
G.R. No. 136351, July 28, 1999
Joel G. Miranda, petitioner, vs. Antonio M. Abaya and the Commission on Elections, respondents.
FACTS
Jose “Pempe” Miranda, incumbent mayor of Santiago City, Isabela, filed his certificate of candidacy for re-election in the May 1998 polls. Antonio Abaya filed a petition to deny due course to or cancel said certificate, alleging Miranda was ineligible for a fourth consecutive term. The COMELEC First Division disqualified Jose Miranda on May 5, 1998. The resolution became final as no motion for reconsideration was filed. Subsequently, on May 6, 1998, Joel G. Miranda, the son, filed a certificate of candidacy as a substitute candidate under the same political party (LAMMP). The COMELEC En Banc included Joel in the certified list of candidates. In the elections, Joel Miranda won over Abaya. Abaya then filed a petition to declare the substitution null and void, arguing that the cancellation of the original certificate left nothing to substitute, and that the substitution was prematurely filed before the period for reconsideration had lapsed.
ISSUE
The primary issue is whether Joel G. Miranda was validly substituted as a candidate following the disqualification of his father, Jose Miranda, thereby entitling him to be proclaimed the winning mayor.
RULING
The Supreme Court, through the majority opinion, ruled in favor of Joel Miranda, upholding the validity of his substitution and his subsequent proclamation. The legal logic centers on the interpretation of Section 77 of the Omnibus Election Code, which allows a candidate who is “disqualified for any cause” to be substituted by a person belonging to the same political party. The Court held that the disqualification of Jose Miranda under the three-term limit rule constituted a disqualification “for any cause” within the meaning of the law. The fact that his certificate was denied due course did not negate the applicability of the substitution rule. The Court emphasized that the purpose of the substitution provision is to prevent a failure of election and to give effect to the will of the electorate. Since Joel Miranda was nominated by the same party and received the plurality of votes, disallowing the substitution would disenfranchise the voters of Santiago City. The Court also found that the substitution was timely filed in accordance with COMELEC rules and that the technical objection regarding the certificate of nomination was insufficient to invalidate the candidacy. The proclamation was therefore valid.