G.R. No. 221538, September 20, 2016
RIZALITO Y. DAVID, PETITIONER, VS. SENATE ELECTORAL TRIBUNAL AND MARY GRACE POE-LLAMANZARES, RESPONDENTS.

FACTS

Petitioner Rizalito Y. David filed a Petition for Certiorari seeking to nullify the Senate Electoral Tribunal (SET) Decision and Resolution which dismissed his Petition for Quo Warranto against Senator Mary Grace Poe-Llamanzares. David sought to unseat Senator Poe, a foundling discovered in Jaro, Iloilo in 1968 and later adopted by spouses Fernando Poe, Jr. and Susan Roces, on the ground that she is not a natural-born Filipino citizen and is thus disqualified under Article VI, Section 3 of the Constitution. The SET ruled in favor of Senator Poe, holding that as a foundling, she is presumed to be a natural-born citizen.
David challenged this SET ruling before the Supreme Court, arguing that the SET committed grave abuse of discretion. He contended that there is no legal presumption that foundlings are natural-born citizens and that Senator Poe failed to present conclusive proof of her biological parents’ citizenship. The case thus presented fundamental questions regarding the citizenship status of foundlings and the scope of the SET’s constitutional authority.

ISSUE

Whether the Senate Electoral Tribunal committed grave abuse of discretion in dismissing the quo warranto petition and ruling that Senator Mary Grace Poe-Llamanzares, a foundling, is a natural-born Filipino citizen qualified for the office of Senator.

RULING

The Supreme Court DISMISSED the petition. The Court held that the SET did not commit grave abuse of discretion in its determination. The ruling emphasized the constitutional design granting the SET, as a tribunal composed of Senators and Supreme Court Justices, the sole and exclusive jurisdiction to be the judge of all contests relating to the qualifications of its members. Its factual findings and conclusions, when supported by substantial evidence, are beyond the scope of certiorari review absent a clear showing of grave abuse amounting to a whimsical or arbitrary exercise of power.
On the substantive issue, the Court clarified that while the Constitution does not explicitly address foundlings, its words cannot be read to callously exclude them from public service. The SET correctly applied the presumption that a foundling is a natural-born citizen, considering the circumstances of her discovery in the Philippines, her continuous possession of Philippine citizenship through official documents (passport, voter’s ID), and the absence of any evidence suggesting foreign parentage. This presumption, rooted in international law principles and the constitutional intent to avoid statelessness, satisfies the quantum of proof required. The Court stressed that this case does not definitively rule on the status of all foundlings, as each case is unique, but found that the SET’s inference from the evidence was reasonable and not tainted by grave abuse of discretion.