Primary Holding

The Supreme Court held that the COMELEC did not commit grave abuse of discretion in dismissing the petition to disqualify FPJ, as the petitioners failed to prove that FPJ deliberately misrepresented his citizenship in his certificate of candidacy.

Background

The case arose when Victorino X. Fornier filed a petition before the COMELEC to disqualify FPJ from running for president, alleging that FPJ was not a natural-born Filipino citizen. The COMELEC dismissed the petition, and Fornier, along with other petitioners, elevated the case to the Supreme Court.

Facts

• 1. FPJ was born on August 20, 1939, to Allan F. Poe and Bessie Kelley.
• 2. Allan F. Poe was allegedly a Spanish citizen, and Bessie Kelley was an American citizen.
• 3. FPJ claimed to be a natural-born Filipino citizen in his certificate of candidacy.
• 4. Fornier alleged that FPJ’s parents were foreigners, making him ineligible for the presidency.
• 5. The COMELEC dismissed the petition, finding no substantial evidence to support Fornier’s claims.

Arguments of the Petitioners

• 1. FPJ is not a natural-born Filipino citizen because his parents were foreigners.
• 2. FPJ’s father, Allan F. Poe, was a Spanish citizen, and his mother, Bessie Kelley, was an American citizen.
• 3. FPJ’s birth certificate and other documents allegedly showed that he was not a natural-born Filipino.
• 4. FPJ’s alleged illegitimacy meant he followed his mother’s citizenship, making him an American.

Arguments of the Respondents

• 1. FPJ is a natural-born Filipino citizen because his father, Allan F. Poe, was a Filipino citizen.
• 2. FPJ’s grandfather, Lorenzo Pou, was a Spanish subject who became a Filipino citizen under the Philippine Bill of 1902.
• 3. FPJ’s birth certificate and other documents showed that he was a Filipino citizen.
• 4. The petitioners failed to prove that FPJ deliberately misrepresented his citizenship.

Issues

• 1. Whether the COMELEC committed grave abuse of discretion in dismissing the petition to disqualify FPJ.
• 2. Whether FPJ is a natural-born Filipino citizen.
• 3. Whether the Supreme Court has jurisdiction over the petitions filed directly before it.

Ruling

• 1. The Supreme Court ruled that the COMELEC did not commit grave abuse of discretion in dismissing the petition to disqualify FPJ.
• 2. The Court found that the petitioners failed to prove that FPJ deliberately misrepresented his citizenship in his certificate of candidacy.
• 3. The Court also ruled that the issue of FPJ’s citizenship could not be conclusively determined in a pre-election proceeding under Section 78 of the Omnibus Election Code.
• 4. The Court emphasized that the citizenship issue could be raised in a post-election quo warranto proceeding if FPJ won the election.
• 5. The Court dismissed the petitions for lack of jurisdiction and failure to show grave abuse of discretion by the COMELEC.

Doctrines

• 1. Jus Sanguinis: Citizenship is determined by blood relationship, not by place of birth.
• 2. Natural-Born Citizen: A natural-born citizen is one who is a citizen from birth without having to perform any act to acquire or perfect their citizenship.
• 3. Grave Abuse of Discretion: A decision is considered to have been made with grave abuse of discretion if it is despotic, arbitrary, or capricious.

Key Excerpts

• 1. “Citizenship is a treasured right conferred on those whom the state believes are deserving of the privilege.”
• 2. “The issue of citizenship is brought up to challenge the qualifications of a presidential candidate to hold the highest office of the land.”

Precedents Cited

• 1. Morano v. Vivo: Cited for the principle that illegitimate children follow the citizenship of their mother.
• 2. Chiongbian v. De Leon: Cited for the principle that illegitimate children do not follow the citizenship of their father.
• 3. Serra v. Republic: Cited for the principle that illegitimate children follow the citizenship of their mother.
• 4. Paa v. Chan: Cited for the principle that illegitimate children do not follow the citizenship of their father.

Statutory and Constitutional Provisions

• 1. Article VII, Section 4, Paragraph 7 of the 1987 Constitution: Grants the Supreme Court exclusive jurisdiction over presidential election contests.
• 2. Section 78 of the Omnibus Election Code: Allows for the denial or cancellation of a certificate of candidacy based on material misrepresentation.