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Facts:

Petitioners sought for respondent Poes disqualification in the presidential


elections for having allegedly misrepresented material facts in his (Poes)
certificate of candidacy by claiming that he is a natural Filipino citizen despite his
parents both being foreigners. Comelec dismissed the petition, holding that Poe
was a Filipino Citizen. Petitioners assail the jurisdiction of the Comelec,
contending that only the Supreme Court may resolve the basic issue on the case
under Article VII, Section 4, paragraph 7, of the 1987 Constitution.

Issues:
1. Whether or not as the Presidential Electoral Tribunal, does the Supreme
Court have jurisdiction over the qualifications of presidential candidates?
2. Whether or not the Comelec committed grave abuse of discretion in
holding that Poe was a Filipino citizen.

Ruling:
1.

No. An examination of the phraseology in Rule 12, 13, and Rule 14 of the
"Rules of the Presidential Electoral Tribunal," promulgated by the Supreme
Court on April 1992 categorically speak of the jurisdiction of the tribunal
over contests relating to the election, returns and qualifications of the
"President" or "Vice-President", of the Philippines, and not of "candidates"
for President or Vice-President. A quo warranto proceeding is generally
defined as being an action against a person who usurps, intrudes into, or
unlawfully holds or exercises a public office. In such context, the election
contest can only contemplate a post-election scenario. In Rule 14, only a
registered candidate who would have received either the second or third
highest number of votes could file an election protest. This rule again
presupposes
a
post-election
scenario.
It is fair to conclude that the jurisdiction of the Supreme Court, defined by
Section 4, paragraph 7, of the 1987 Constitution, would not include cases
directly brought before it, questioning the qualifications of a candidate for
the presidency or vice-presidency before the elections are held.

2. Comelec did not commit grave abuse of discretion in holding Poe as a


Filipino Citizen.
The 1935 Constitution on Citizenship, the prevailing fundamental law on
respondents birth, provided that among the citizens of the Philippines are "those
whose fathers are citizens of the Philippines."
Tracing respondents paternal lineage, his grandfather Lorenzo, as evidenced
by the latters death certificate was identified as a Filipino Citizen. His citizenship

was also drawn from the presumption that having died in 1954 at the age of 84,
Lorenzo would have been born in 1980. In the absence of any other evidence,
Lorenzos place of residence upon his death in 1954 was presumed to be the
place of residence prior his death, such that Lorenzo Pou would have benefited
from the "en masse Filipinization" that the Philippine Bill had effected in 1902.
Being so, Lorenzos citizenship would have extended to his son, Allan--respondents father.
Respondent, having been acknowledged as Allans son to Bessie, though an
American citizen, was a Filipino citizen by virtue of paternal filiation as
evidenced by the respondents birth certificate. The 1935 Constitution on
citizenship did not make a distinction on the legitimacy or illegitimacy of the
child, thus, the allegation of bigamous marriage and the allegation that
respondent was born only before the assailed marriage had no bearing on
respondents citizenship in view of the established paternal filiation evidenced by
the public documents presented.
But while the totality of the evidence may not establish conclusively that
respondent FPJ is a natural-born citizen of the Philippines, the evidence on hand
still would preponderate in his favor enough to hold that he cannot be held guilty
of having made a material misrepresentation in his certificate of candidacy in
violation of Section 78, in relation to Section 74 of the Omnibus Election Code.