Case Digest on Administrative Law Case Facts :MANUEL B. JAPZON vs. COMMISSION ON ELECTIONS and JAIME S.

TY :

Manuel B. Japzon and private respondent Jaime S. Ty were candidates for the Office of Mayor in the local elections held on May 2007. Japzon filed a petition to disqualify Tys Certificate of Candidacy on the ground of material misrepresentation when the latter falsely represented therein that he was a resident of Barangay 6, Poblacion, General Macarthur, Eastern Samar, for one year before 14 May 2007, and that he was not a permanent resident or immigrant of any foreign country. Ty admitted that he was a natural-born Filipino who went to the USA to work and subsequently became a naturalized American citizen. However, he further claims that he had reacquired his Philippine citizenship through Republic Act No. 9225, which grants dual citizenship to natural-born Filipinos, and subsequently renounced his American citizenship through an execution of a duly notarized Renunciation of Foreign Citizenship. He further claims that he had been a resident of the Municipality of General Macarthur, Eastern Samar for more than one year prior to the May 2007 elections exhibiting his passport issued on 2005 bearing the aforementioned residence community tax certificates for the years 2006 and 2007, respectively, and his registration as a voter in Barangay 6, Poblacion, General MacArthur, Eastern Samar. Ty won the elections and was proclaimed Mayor of the Municipality of General Macarthur, Eastern Samar. The COMELEC ruled in favor of the private respondent. Issue :

Whether a determination of a question of fact by the COMELEC, in the instant case, Tys compliance of the one-year residency requirement for running for public office, requires the Court to review, examine and evaluate or weigh the probative value of the evidence presented by the parties before the COMELEC. Held :

The Court found no merit in the petition at bar. Factual findings of administrative agencies, such as the COMELEC, which have acquired expertise in their field are binding and conclusive on the Court. The Court cannot evaluate again the very same pieces of evidence without violating the well-entrenched rule that findings of fact of the COMELEC are binding on the Court. The findings of facts of quasi-judicial agencies which have acquired expertise in the specific matters entrusted to their jurisdiction are accorded by the Court not only respect but even finality if they are supported by substantial evidence. Only substantial, not preponderance, of evidence is necessary. The resolutions assailed by the COMELEC were supported by substantial evidence and are, thus, binding and conclusive upon the Court.

Case Digest on Administrative Law Case Facts : RONNIE H. LUMAYNA, et. al. vs. COMMISSION ON AUDIT :

The Department of Budget and Management granted a maximum of five percent salary adjustment to personnel in the Local Government Units pursuant to Republic Act No. 9137 and issued a circular providing guidelines on personal services limitation pursuant to the Local Government Code. In pursuance thereof, a 2003 Annual Municipal Budget resolution was enacted by the Sangguniang Bayan of Mayoyao, Ifugao adopting a first class salary scheme for the municipality and implementing a five percent salary increase for its personnel re-aligning the amount originally appropriated in their 2002 Annual Municipal Budget for the salaries and benefits of seventeen new positions. The Sangguniang Panlalawigan disallowed the said increase and the re-alignment of funds on the ground that the re-alignment is not sufficient in form to implement a salary increase but finding good faith on the part of the officials of the municipality, it reconsidered. The Commission on Audit subsequently issued a Notice of Disallowance for the salary increases of municipal personnel and ordered herein petitioners to refund the amount contending that the increase was not in accordance with the Local Government Code; that the limitation on personal services had been exceeded; and that the Sangguniang Bayan resolution was not the appropriate manner of granting the increase. Issue :

Whether the Commission on Audit gravely abused its discretion when it upheld the notice of disallowance which directed the herein petitioners to refund the amount disallowed therein. Held :

The Court partially granted the instant petition on the basis of the petitioners good faith but found that the Commission on Audit correctly affirmed the disallowance of the amount. Findings of fact by administrative bodies charged with their specific field of expertise, are afforded great weight by the courts, and in the absence of substantial showing that such findings were made from an erroneous estimation of the evidence presented, they are conclusive and should not be disturbed in the interest of stability of the governmental structure. The decisions of the commission clearly presented the factual findings and adequately explained the legal basis for disallowing the said amount. The Court found no grave abuse of discretion on the part of the respondent commission.