G.R. No. 256053, November 05, 2024
VICE MAYOR PETER BASCON MIGUEL, PETITIONER, VS. ELIORDO USERO OGENA, RESPONDENT.

FACTS

Petitioner Peter Bascon Miguel and respondent Eliordo Usero Ogena were elected Vice Mayor and Mayor, respectively, of Koronadal City in the May 13, 2019 elections, proclaimed on May 15, 2019, and assumed office on June 30, 2019. On August 29, 2019, Miguel filed a Complaint for quo warranto before the Regional Trial Court (RTC) against Ogena, alleging Ogena was disqualified from holding elective office under Section 40(a) and (b) of the Local Government Code. The ground was the penalties imposed on Ogena by the Supreme Court in an administrative case (AC No. 9807): a two-year suspension from the practice of law and a permanent ban from performing notarial service for violating the 2004 Rules on Notarial Practice. Ogena argued the RTC lacked jurisdiction, asserting the Commission on Elections (COMELEC) had exclusive jurisdiction over such contests, and questioned Miguel’s personality to file the suit. The RTC initially granted the quo warranto complaint on March 5, 2020, finding Ogena disqualified. Upon Ogena’s motion for reconsideration, the RTC reversed itself in a July 7, 2020 Resolution, dismissing the complaint for lack of jurisdiction, holding that COMELEC has exclusive jurisdiction. The Court of Appeals affirmed the RTC’s dismissal in its Decision dated December 15, 2020.

ISSUE

Whether the Regional Trial Court has jurisdiction over a quo warranto petition challenging the eligibility of a duly proclaimed and incumbent city mayor based on a disqualification under the Local Government Code.

RULING

No. The Supreme Court affirmed the rulings of the Court of Appeals and the Regional Trial Court, holding that the COMELEC has exclusive original jurisdiction over contests relating to the qualifications of an elective city official like the Mayor of Koronadal City. The Court ruled that a quo warranto petition questioning the eligibility of a proclaimed candidate for an elective local office, filed after proclamation and assumption of office, falls within the exclusive original jurisdiction of the COMELEC, pursuant to Section 2(2), Article IX-C of the 1987 Constitution and Section 253 of the Omnibus Election Code. The RTC, therefore, correctly dismissed the petition for lack of jurisdiction. The Court emphasized that the remedy of a regular quo warranto under Rule 66 of the Rules of Court is not the proper vehicle to assail the title to an elective local office; the appropriate remedy is an election contest or a quo warranto petition filed within the period prescribed by election laws before the COMELEC. The Court did not reach the substantive issue of whether Ogena’s administrative penalties constituted grounds for disqualification under the Local Government Code, as the case was resolved solely on the jurisdictional issue.