A candidate previously declared by a final Supreme Court judgment to be a non-Filipino citizen remains disqualified from running for and holding public office unless reacquisition of Philippine citizenship is proven; winning an election does not cure such ineligibility, and the candidate receiving the second-highest number of votes is not entitled to be proclaimed the winner, with the vacancy to be filled by operation of the rule on succession (i.e., by the vice-mayor elect).

This case arose after Ramon L. Labo, Jr., despite a previous Supreme Court ruling in 1989 (Labo v. Commission on Elections, 176 SCRA 1) declaring him not a Filipino citizen, filed a certificate of candidacy for Mayor of Baguio City in the May 11, 1992 elections, asserting he was a "natural-born" Filipino. Roberto Ortega, another mayoral candidate, subsequently filed a disqualification case against Labo before the Commission on Elections (Comelec) based on this prior judgment and Labo's alleged false representation of citizenship.

• Ramon L. Labo, Jr. filed his certificate of candidacy for Mayor of Baguio City on March 23, 1992, declaring himself a "natural-born" Filipino citizen, despite a 1989 Supreme Court decision (Labo v. Comelec) finding him not to be a Filipino citizen.
• Roberto C. Ortega, another mayoral candidate, filed a disqualification case against Labo with the Comelec on March 26, 1992, alleging false material representation regarding Labo's citizenship.
• Labo failed to file a timely Answer to the disqualification petition; he submitted his Answer only on May 5, 1992, after Ortega had presented evidence (including the 1989 Supreme Court decision) at a hearing on May 4, 1992, where Labo's counsel was present but offered no evidence.
• On May 9, 1992, the Comelec granted Ortega's petition, cancelled Labo's certificate of candidacy, and ordered his name removed from the list of candidates.
• On May 10, 1992, the Comelec clarified that its May 9 resolution would become final and executory five days after promulgation, allowing Labo to be voted for in the May 11, 1992 elections, subject to the case's final outcome.
• Labo received the highest number of votes (27,471) in the May 11, 1992 mayoral election; Ortega received the second-highest (12,602 votes).
• On May 13, 1992, the Comelec resolved motu proprio to suspend Labo's proclamation if he won.
• Labo claimed he had a pending application for reacquisition of Philippine citizenship under PD 725 and LOI No. 270, which had a favorable recommendation from the Solicitor General but no final action by the Special Committee on Naturalization.

• (Ramon L. Labo, Jr. in G.R. No. 105111) Labo asserted his Filipino citizenship, claimed denial of due process in the Comelec proceedings, and argued that no specific finding of intent to renounce Philippine citizenship was made against him.
• (Ramon L. Labo, Jr. in G.R. No. 105111) Labo contended that Sec. 72 of the Omnibus Election Code (allegedly a special repatriation proceeding) allowed his proclamation as the disqualification was not yet final at election time, and that he had effectively reacquired citizenship through a pending repatriation application.
• (Roberto C. Ortega in G.R. No. 105384) Ortega argued that the Comelec's May 9, 1992 resolution disqualifying Labo was final and executory, and that Comelec gravely abused its discretion by not implementing it.
• (Roberto C. Ortega in G.R. No. 105384) Ortega claimed that due to Labo's disqualification, he, as the candidate with the next highest number of votes, should be proclaimed Mayor of Baguio City.

• (Commission on Elections, respondent in both G.R. Nos. 105111 & 105384) The Comelec maintained that Labo was not a Filipino citizen based on the Supreme Court's 1989 ruling, and that Labo failed to present evidence of reacquiring citizenship, thus justifying the cancellation of his certificate of candidacy.
• (Commission on Elections, respondent in G.R. No. 105384) The Comelec justified its non-implementation of the May 9 resolution by citing Labo's pending petition before the Supreme Court.
• (Ramon L. Labo, Jr., respondent in G.R. No. 105384) Labo argued his disqualification was not yet final due to his appeal to the Supreme Court.

• Whether Ramon L. Labo, Jr. was qualified to run for and hold the office of Mayor of Baguio City, particularly concerning his Philippine citizenship.
• Whether the Comelec committed grave abuse of discretion in cancelling Labo's certificate of candidacy due to false material representation of his citizenship.
• Whether the Comelec's May 9, 1992 resolution disqualifying Labo became final and executory.
• Whether Roberto C. Ortega, as the candidate with the second-highest number of votes, was entitled to be proclaimed Mayor upon Labo's disqualification.
• How the permanent vacancy created by Labo's ineligibility in the office of Mayor of Baguio City should be filled.

• The Supreme Court dismissed both petitions (G.R. No. 105111 and G.R. No. 105384) for lack of merit.
• The Court affirmed Labo's disqualification, reiterating that he was not a Filipino citizen as per the 1989 Labo v. Comelec decision, and he failed to present any evidence of having reacquired Philippine citizenship; a mere pending application for repatriation does not suffice.
• The Court found no grave abuse of discretion by the Comelec in cancelling Labo's certificate of candidacy, as it was bound by the prior Supreme Court ruling and Labo's failure to prove citizenship or its reacquisition.
• The Court held that the Comelec's May 9, 1992 resolution cancelling Labo's certificate of candidacy became final and executory on May 14, 1992, five days after Labo's receipt thereof, as no restraining order was issued by the Supreme Court.
• The Court ruled that Roberto Ortega, the second-placer, was not entitled to be proclaimed Mayor, as the disqualification of the winning candidate does not automatically result in the proclamation of the candidate with the next highest votes; the electorate did not choose Ortega.
• The Court declared that Labo's ineligibility created a permanent vacancy in the office of Mayor, which must be filled by the duly elected Vice-Mayor of Baguio City pursuant to Section 44 of the Local Government Code.

• Citizenship as an Indispensable Qualification for Public Office — An elective local official must be a citizen of the Philippines (Sec. 39, Local Government Code). This qualification is fundamental and cannot be waived by election. Labo's non-Filipino status, previously declared by the Court, rendered him ineligible.
• Binding Effect of Prior Judgment on Citizenship — A final judicial declaration on citizenship status is binding in subsequent proceedings unless there is proof of reacquisition of such citizenship. The Court's 1989 decision declaring Labo not a Filipino citizen bound the Comelec and the Court in this case, as Labo presented no proof of reacquisition.
• False Material Representation in Certificate of Candidacy — A statement in a certificate of candidacy that is false, such as a claim to Philippine citizenship by one who is not a citizen, constitutes false material representation and is a ground for cancelling the certificate. Labo's claim to be a "natural-born" Filipino was false.
• Finality of Comelec Decisions — Decisions of the Comelec in petitions to deny due course or cancel certificates of candidacy become final and executory five days after receipt by the parties, unless restrained by the Supreme Court (Sec. 78, Omnibus Election Code; Sec. 3, Rule 39, Comelec Rules of Procedure). Labo's disqualification became final as no TRO was timely issued.
• Rejection of the Second-Placer Rule — The candidate who garners the second highest number of votes is not entitled to be proclaimed the winner if the candidate who received the highest number of votes is disqualified, particularly when the disqualification was not notoriously known to the electorate before the election. The will of the electorate in choosing the disqualified candidate (albeit mistakenly believing him qualified) cannot be overridden by proclaiming a candidate who lost the election.
• Succession in Case of Permanent Vacancy in Local Office — If a permanent vacancy occurs in the office of the mayor, the vice-mayor shall become the mayor (Sec. 44, Local Government Code). This rule applies when the elected mayor is found ineligible.
• Reacquisition of Philippine Citizenship — Philippine citizenship may be reacquired by direct act of Congress, naturalization, or repatriation (CA No. 63, as amended by PD No. 725). A mere application for repatriation, even with a favorable recommendation, does not constitute reacquisition without official approval and completion of the process.

• "The fact that he was elected by the people ... does not excuse this patent violation of the salutary rule limiting public office and employment only to the citizens of this country. The qualification prescribed for elective office cannot be erased by the electorate alone. The will of the people as expressed through the ballot cannot cure the vice of ineligibility, especially if they mistakenly believed, as in this case, that the candidate was qualified." (Citing Frivaldo v. Commission on Elections)
• "What matters is that in the event a candidate for an elected position who is voted for and who obtains the highest number of votes is disqualified for not possessing the eligibility requirements at the time of the election as provided by law, the candidate who obtains the second highest number of votes for the same position cannot assume the vacated position." (Citing Abella v. Comelec)
• "Sound policy dictates that public elective offices are filled by those who have received the highest number of votes cast in the election for that office, and it is a fundamental idea in all republican forms of government that no one can be declared elected and no measure can be declared carried unless he or it receives a majority or plurality of the legal votes cast in the election." (Citing Geronimo v. Santos)
• "Whether or not the candidate whom the majority voted for can or cannot be installed, under no circumstances can a minority or defeated candidate be deemed elected to the office."

• Labo v. Commission on Elections (176 SCRA 1 [1989]) — Served as the primary basis for Labo's disqualification in the present case, as it previously declared Labo not a Filipino citizen.
• Frivaldo v. Commission on Elections (174 SCRA 245 [1989]) — Cited to emphasize that election by the populace does not cure a candidate's ineligibility, particularly lack of citizenship.
• Abella v. Comelec (201 SCRA 253 [1991]) — Relied upon as controlling precedent for the rule that the second-placer in an election cannot be proclaimed winner if the first-placer is disqualified post-election.
• Geronimo v. Santos (136 SCRA 435) — Referenced for the democratic principle that public office is filled by those receiving the highest number of votes and that a minority candidate cannot be imposed on the electorate; this case supports the rejection of the second-placer rule.
• Topacio vs. Paredes (23 Phil. 238) — Mentioned as an early case establishing the doctrine against proclaiming the second-placer, which was reiterated in Geronimo v. Santos.
• Vance v. Terrazas (444 US 252) — Cited by Labo on the requirements for proving expatriation; the Court found no need to re-examine this as it was previously considered.

• Sec. 39, Local Government Code (RA 7160) — Its provision requiring an elective local official to be a citizen of the Philippines was central to Labo's disqualification.
• Sec. 44, Local Government Code (RA 7160) — Its provision on succession by the vice-mayor in case of a permanent vacancy in the mayor's office was applied to resolve the leadership issue in Baguio City.
• Sec. 78, Omnibus Election Code — Its provision on the finality of Comelec decisions (after five days unless stayed by the Supreme Court) was applied to determine that Labo's disqualification resolution had become final and executory.
• Sec. 3, Rule 39, Comelec Rules of Procedure — Cited for its similar provision on the finality of Comelec decisions regarding disqualification cases.
• Sec. 6, Republic Act No. 6646 (Electoral Reforms Law of 1987) — Referenced as having repealed Sec. 72 of the Omnibus Election Code and for its provisions on the effect of disqualification cases, including the suspension of proclamation.
• Commonwealth Act No. 63, as amended by Presidential Decree No. 725 — Cited in relation to the methods of reacquiring Philippine citizenship, which Labo failed to prove he had accomplished.
• Presidential Decree No. 725 and Letter of Instruction No. 270 — Referenced in Labo's claim of a pending application for repatriation, which the Court found insufficient to establish reacquired citizenship.

• Justice Hugo E. Gutierrez, Jr. — Concurred with the majority's ruling that in the event of a mayor-elect's disqualification, the vice-mayor elect succeeds to the office, and not the candidate who received the second-highest number of votes for mayor, consistent with his ponencia in Geronimo v. Santos.

• Justice Hugo E. Gutierrez, Jr. — Dissented from the majority's finding that Ramon L. Labo, Jr. lost his Philippine citizenship and was therefore disqualified. He reiterated his position from the 1989 Labo case that Labo never validly acquired Australian citizenship (as his marriage to an Australian, which was the basis for his Australian citizenship application, was bigamous and void), thus his oath of allegiance to Australia was meaningless and could not divest him of his natural-born Philippine citizenship. He argued Labo should have been proclaimed mayor and emphasized that presumptions in citizenship cases should favor retention.