GR 193261; (April, 2012) (Digest)
G.R. No. 193261; April 24, 2012
Meynardo Sabili, Petitioner, vs. Commission on Elections and Florencio Librea, Respondents.
FACTS
Petitioner Meynardo Sabili filed his Certificate of Candidacy (COC) for Mayor of Lipa City for the May 2010 elections, declaring therein a two-year and eight-month residency. Private respondent Florencio Librea filed a petition to deny due course and cancel Sabili’s COC, alleging a material misrepresentation regarding his compliance with the one-year residency requirement under the Local Government Code. Librea presented evidence, including Sabili’s 2007 COC for Congressman where he indicated residence in San Juan, Batangas, and various certifications suggesting his family’s lack of established ties to Lipa City.
Sabili countered with evidence to prove his Lipa City residency, including a barangay certification, affidavits from neighbors, his 2008 and 2009 Income Tax Returns (ITRs) filed in Lipa City, and a COMELEC application for transfer of voter’s registration. The COMELEC Second Division granted Librea’s petition, canceling Sabili’s COC for failure to meet the residency requirement. Sabili’s motion for reconsideration was pending when the elections were held, and he was proclaimed the elected Mayor. The COMELEC En Banc subsequently denied his motion.
ISSUE
Whether the COMELEC committed grave abuse of discretion in denying due course to and canceling Sabili’s Certificate of Candidacy for alleged material misrepresentation regarding his residency.
RULING
No, the COMELEC did not commit grave abuse of discretion. The Supreme Court upheld the COMELEC’s factual findings, emphasizing that residency for election purposes involves both the intention to reside and personal presence in the locality. The Court found Sabili’s evidence insufficient to overturn the COMELEC’s conclusion. While his ITRs indicated Lipa City as his place of business/residence, they were not conclusive proof of physical presence and domiciliary intent, especially when weighed against his prior COC declaring a different domicile. His application for voter transfer in June 2009 also fell short of the one-year requirement.
The Court ruled that the COMELEC’s assessment of the conflicting evidence was not tainted with arbitrariness. It stressed that the purpose of the residency requirement is to ensure that candidates possess a genuine familiarity with the locality’s needs and conditions. The COMELEC’s conclusion that Sabili failed to prove an actual change of domicile from San Juan, Batangas, to Lipa City one year before the elections was supported by substantial evidence. Therefore, the misrepresentation in his COC was material, warranting its cancellation.