Primary Holding

The Supreme Court ruled that Imelda Romualdez-Marcos met the residency requirement to run for Congress in the First District of Leyte, overturning the disqualification issued by the COMELEC.

Background

Imelda Romualdez-Marcos filed her Certificate of Candidacy (COC) for Representative of the First District of Leyte, declaring seven months of residency. Her political opponent, Cirilo Roy Montejo, filed a petition to disqualify her on the grounds of failing to meet the one-year residency requirement. Marcos later amended her COC, stating that she had been a resident "since childhood," but the COMELEC refused to accept this correction and ruled her disqualified. The Supreme Court reviewed the case and reversed the COMELEC's decision.

Facts

• 1. Imelda Romualdez-Marcos indicated in her initial COC that she had been a resident of the First District of Leyte for only seven months.
• 2. Montejo challenged this, citing her voter registration record.
• 3. Marcos attempted to amend her COC to clarify that she had been a resident "since childhood."
• 4. COMELEC refused to accept the amendment and ruled her disqualified.
• 5. Despite winning the congressional election, her proclamation was suspended.
• 6. The Supreme Court later ruled that she had continuously maintained her domicile in Leyte.

Arguments of the Petitioners

• 1. Marcos argued that her initial statement of "seven months" was an honest mistake.
• 2. She claimed that she had always intended to return to Leyte and that Tacloban was her domicile of origin.
• 3. She pointed out that her ties to Leyte, including family properties and public projects, indicated her permanent association with the district.

Arguments of the Respondents

• 1. Montejo and COMELEC asserted that Marcos did not meet the one-year residency requirement.
• 2. They argued that her voter registration and previous declarations indicated that she resided in Metro Manila.
• 3. COMELEC contended that she could not amend her COC after the filing deadline had lapsed.

Issues

• 1. Whether Marcos met the one-year residency requirement for congressional candidates.
• 2. Whether COMELEC acted within its jurisdiction in disqualifying Marcos and preventing her proclamation.
• 3. Whether the House of Representatives Electoral Tribunal (HRET) should have jurisdiction over the case after the election.

Ruling

• 1. The Supreme Court ruled that residence in election law is synonymous with domicile, which Marcos had continuously maintained in Tacloban, Leyte.
• 2. The Court found that the amendment to her COC should have been accepted, as it merely corrected an honest mistake.
• 3. COMELEC’s refusal to accept the amendment and its ruling against Marcos were declared erroneous.
• 4. Marcos was deemed qualified to run, and her proclamation was ordered.

Doctrines

• 1. Residence vs. Domicile: The Court reiterated that "residence" in election law refers to "domicile," which is not lost by temporary relocation.
• 2. Animus Manendi and Animus Non Revertendi: The intent to remain or return determines domicile.
• 3. Jurisdiction of HRET: The jurisdiction over a congressional seat shifts to HRET only after a candidate has assumed office.

Key Excerpts

• 1. “A constitutional provision should be construed as to give it effective operation and suppress the mischief at which it is aimed.”
• 2. “It is the fact of residence, not a statement in a certificate of candidacy, which ought to be decisive in determining whether or not an individual has satisfied the Constitution’s residency qualification requirement.”

Precedents Cited

• 1. Faypon v. Quirino (1955): Residence in election law is synonymous with domicile.
• 2. Romualdez v. RTC-Tacloban (1993): Defined domicile and how it is retained.
• 3. Nuval v. Guray (1915): Established that residence is synonymous with domicile in election cases.

Statutory and Constitutional Provisions

• 1. 1987 Constitution, Article VI, Section 6: Residency requirement for members of the House of Representatives.
• 2. Omnibus Election Code (B.P. Blg. 881), Section 78: Procedure for cancellation of COCs.