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MARIA JEANETTE C. TECSON v. COMELEC

FACTS:

Ronald Allan Kelly Poe, better known as Fernando Poe Jr. (FPJ), filed his certificate of candidacy for President of the Philippines on December 31, 2003, listing himself as a natural-born Filipino citizen. Victorino X. Fornier contested FPJ’s candidacy, alleging that FPJ falsely claimed to be natural-born, arguing that FPJ’s parents were foreigners: his mother was American, and his father was Spanish. Fornier further contended that FPJ was an illegitimate child because his father had married someone else before FPJ’s mother. In COMELEC hearings, Fornier presented documentary evidence, including birth and marriage certificates, an affidavit from a supposed previous spouse of FPJ's father, and archival records, to support his claims. FPJ countered with 22 documents, including birth and marriage certificates, property titles, tax declarations, and certifications from archival offices, asserting his Filipino lineage. COMELEC dismissed Fornier's petition, and subsequent motions for reconsideration, for lack of evidence and merit. Fornier, along with other parties, elevated the issue to the Supreme Court, raising questions on jurisdiction and the qualifications of FPJ's candidacy. The core legal issue revolved around the legitimacy and natural-born status of FPJ under Philippine law, amidst conflicting historical records and legal interpretations.

ISSUES:

  1. Whether or not Fernando Poe, Jr. (FPJ) is a natural-born Filipino citizen.

  2. Whether the Supreme Court has jurisdiction over petitions questioning the qualifications of a presidential candidate before elections are held.

RULING:

  1. Issue on Natural-born Citizenship

    • Ruling The evidence presented preponderates in favor of Fernando Poe, Jr. being a natural-born Filipino citizen. Consequently, there's no material misrepresentation in his certificate of candidacy.

  2. Issue on Supreme Court’s Jurisdiction

    • Ruling The Supreme Court does not have jurisdiction over the petitions (G.R. Nos. 161434 and 161634) questioning the qualifications of a presidential candidate before the elections, as stipulated in the Constitution.

PRINCIPLES:

  1. Citizenship

    • The four modes for acquiring citizenship (Naturalization, jus soli, res judicata, and jus sanguinis) applied historically, with jus sanguinis being the primary mode under the 1935 Constitution.

    • Citizenship principles from the Civil Code and Family Code were used to ascertain legitimacy and filiation but centralized in the principles that a person whose father is a Filipino citizen is also a Filipino, regardless of legitimacy.

  2. Judicial Review and Certiorari

    • The Supreme Court has the power to review decisions of the COMELEC on the grounds of grave abuse of discretion under Rule 64 and Rule 65 of the Revised Rules of Civil Procedure.

  3. Exclusive Jurisdiction of the Supreme Court Post-Election

    • Article VII, Section 4, Paragraph 7, of the 1987 Constitution grants the Supreme Court sole jurisdiction over presidential and vice-presidential election contests post-election.

  4. Proof of Filiation

    • Proof of filiation for citizenship determination may involve various forms of documentary evidence and declarations, with additional possibilities such as DNA testing for establishing paternity if documentary evidence is insufficient or questionable.

  5. Employment of Rules on Public Documents

  • Public documents, including birth, death, and marriage certificates, are considered prima facie evidence of the facts stated. The Rules of Court govern the evidentiary weight given to such documents in establishing citizenship.