Hayudini v.

Comelec
Facts:
Hayudini filed his Certificate of Candidacy (CoC) for the position of Municipal
Mayor of South Ubian, Tawi-Tawi in the May 13, 2013 National and Local
Elections held in the Autonomous Region in Muslim Mindanao. Ten days after,
Mustapha J. Omar (Omar) filed a Petition to Deny Due Course or Cancel
Hayudinis CoC, Omar basically asserted that Hayudini should be disqualified
for making false representation regarding his residence. He claimed that
Hayudini declared in his CoC that he is a resident of the Municipality of South
Ubian when, in fact, he resides in Zamboanga City.
Thereafter, Hayudini filed a Petition for Inclusion in the Permanent List of
Voters in Barangay Bintawlan, South Ubian before the Municipal Circuit Trial
Court (MCTC). Despite the opposition of Ignacio Aguilar Baki, the MCTC
granted Hayudinis petition. On that same day, the COMELEC dismissed
Omars earlier petition to cancel Hayudinis CoC for lack of substantial
evidence that Hayudini committed false representation as to his residency.
Oppositor Baki, subsequently, elevated the case to the Bongao Regional Trial
Court. The RTC reversed the MCTC ruling and ordered the deletion of
Hayudinis name in Barangay Bintawlans permanent list of voters. In view of
said decision, Omar filed before the COMELEC a Petition to Cancel the
Certificate of Candidacy of Gamal S. Hayudini by Virtue of a Supervening
Event. Hayudini appealed the decision to the Court of Appeals, but was
denied. Hayudini however, won the mayoralty race. He was proclaimed and,
consequently, took his oath of office. Later on, the COMELEC issued a
Resolution granting Omars second petition to cancel Hayudinis CoC.
Hayudini, thus, filed a Motion for Reconsideration with the COMELEC En Banc,
arguing that its Second Division committed grave error when it gave due
course to a belatedly filed petition and treated RTC Decision as a supervening
event. The COMELEC En Banc denied Hayudinis Motion for Reconsideration
for lack of merit. The COMELEC later on declared Omar as mayor.
Issue:
WON the Comelec committed grave abuse of discretion in its decision and
proclaiming Omar as mayor.
Held:
No. The Court sustains the COMELECs Omars petition. Generally the statutes
providing for election contests are to be liberally construed in order that the
will of the people in the choice of public officers may not be defeated by mere
technical objections. It is neither fair nor just to keep in office, for an
indefinite period, one whose right to it is uncertain and under suspicion. It is
imperative that his claim be immediately cleared, not only for the benefit of
the winner but for the sake of public interest, which can only be achieved by
brushing aside technicalities of procedure that protract and delay the trial of

an ordinary action.
The COMELEC has the power to liberally interpret or even suspend its rules of
procedure in the interest of justice, including obtaining a speedy disposition
of all matters pending before it. This liberality is for the purpose of promoting
the effective and efficient implementation of its objectives to ensure the
holding of free, orderly, honest, peaceful, and credible elections, as well as
achieving just, expeditious, and inexpensive determination and disposition of
every action and proceeding brought before the COMELEC.
The same ruling adequately equipped Omar with the necessary ground to
successfully have Hayudinis CoC struck down. Under the rules, a statement in
a certificate of candidacy claiming that a candidate is eligible to run for public
office when in truth he is not, is a false material representation, a ground for
a petition under Section 78 of the Omnibus Election Code.