Aquino vs COMELEC G.R. No. 120265 September 18, 1995

 Aquino vs COMELEC

G.R. No. 120265 September 18, 1995

Constitutional Law | Legislative Department | Domicile

In the absence of clear and positive proof of successful abandonment of domicile, it shall be deemed continued.

FACTS:

Petitioner Aquino was a resident of Concepcion, Tarlac for over 50 years. He, in fact, indicated in his Certificate of Candidacy for the 1992 congressional elections that he was a resident of thereof for 52 years immediately preceding that election. His birth certificate also places Concepcion, Tarlac as the birthplace of both his parents.

For the 1995 elections, Aquino ran for the Congress representing the new 2nd district of Makati City. He stated in his Certificate of Candidacy that he has resided “in the constituency where” he sought “to be elected” for only “10 months.” He in fact has just transferred to a leased condominium in Makati from his residence in Tarlac. Private respondents filed a petition to disqualify him on the ground that he lacked the residence qualification as a candidate for congressman mandated in Art VI, Sec 6 of the Constitution. The following day, Aquino amended his Certificate of Candidacy, indicating he has been a resident in said place for 1 year and 13 days. Meanwhile, elections were held and he garnered the highest number of votes. However, COMELEC, acting on the private respondents’ petition, suspended his proclamation permanently. Hence this instant petition for certiorari.

ISSUE:

Did Aquino satisfy the constitutional residence requirement in the 2nd district of Makati City as mandated by Art VI, Sec 6?

RULING:

No. The essence of representation is to place through the assent of voters those most cognizant and sensitive to the needs of a particular district. Clearly, Aquino’s domicile of origin was Concepcion, Tarlac, and the same is not easily lost. That coupled with the fact that Aquino himself claims to have other residences in Metro Mla. and that he claims to be resident of the condominium unit in Makati for only a short length of time “indicate that” his “sole purpose in transferring his physical residence” is not to acquire a new residence of domicile “but only to qualify as a candidate for Representative of the 2nd district of Makati City.” The absence of clear and positive proof showing a successful abandonment of domicile under the conditions stated above, the lack of identification— sentimental, actual or otherwise—with the area, and the suspicious circumstances under which the lease agreement [of the condominium unit in Makati (instead of buying one)] was effected all belie his claim of residency for the period required by the Constitution.


The sanctity of the people’s will must be observed at all times if our nascent democracy is to be preserved. In any challenge having the effect of reversing a democratic choice, expressed through the ballot, this Court should be ever so vigilant in finding solutions which would give effect to the will of the majority, for sound public policy dictates that all elective offices are filled by those who have received the highest number of votes cast in an election. When a challenge to a winning candidate’s qualifications however becomes inevitable, the ineligibility ought to be so noxious to the Constitution that giving effect to the apparent will of the people w

 

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