FACTS:

In this case, Richard Gomez filed his certificate of candidacy (CoC) for congressional office, but Buenaventura Juntilla filed a petition alleging that Richard failed to meet the residency requirement. The COMELEC declared Richard disqualified and denied his motion for reconsideration. Richard accepted the resolution with finality, and Lucy Marie Torres-Gomez filed her CoC as the substitute candidate. Juntilla opposed the substitution, arguing that there should be no substitution since Richard's candidacy was disqualified, not canceled. Private respondent won the elections and was proclaimed as the duly-elected Representative. Juntilla filed a motion for reconsideration, but it was unacted. Juntilla then filed a petition for quo warranto to remove private respondent from her congressional seat, alleging non-compliance with election laws.

In the quo warranto petition, petitioner argued that private respondent failed to meet the residency requirement, did not validly substitute her husband as a candidate, and her CoC was void due to non-compliance with notarial requirements. Private respondent denied the allegations and claimed valid substitution. She also argued that she was personally known to the notary public and did not need to present proof of identity. The HRET dismissed the petition and declared private respondent as a qualified candidate, upholding the validity of the substitution and the CoC.

The petitioner filed an appeal to question the HRET's finding on the validity of the substitution. The issue before the Court was whether the HRET gravely abused its discretion in finding the substitution valid. The Court ruled in favor of the petitioner, explaining the distinction between disqualification under Section 68 of the OEC and the denial or cancellation of a CoC under Section 78. They emphasized that a person whose CoC has been denied or cancelled under Section 78 is considered to have not been a candidate at all, regardless of deliberateness or intent to defraud.

ISSUES:

1. Whether a person whose certificate of candidacy (CoC) had been denied due course to or cancelled under Section 78 is considered a candidate for substitution purposes.

2. Whether the existence of a valid CoC is a requirement for candidate substitution.

3. Whether a candidate who is disqualified under Section 68 can be validly substituted pursuant to Section 77.

4. Whether a person whose COC has been denied due course to and/or cancelled under Section 78 can be substituted.

5. Whether material misrepresentation cases can be a valid basis for candidate substitution under Section 77.

6. Whether the COMELEC's grant of the petition in SPA No. 98-019 without any qualification resulted in the disqualification and cancellation of Jose "Pempe" Miranda's certificate of candidacy.

7. Whether the HRET committed grave abuse of discretion in approving the substitution of the private respondent.

8. Whether the private respondent's qualification to run for public office, which was linked to her husband's qualifications, should be subject to quo warranto proceedings falling within the exclusive jurisdiction of the House of Representatives Electoral Tribunal (HRET) and independent from any previous proceedings before the Commission on Elections (COMELEC).

9. Whether the HRET gravely abused its discretion in adopting the flawed findings of the COMELEC regarding the private respondent's eligibility to run for public office.

10. Whether the private respondent was a bona fide candidate for the position of Representative for the Fourth District of Leyte when she ran for office.

RULING:

1. A person whose CoC had been denied due course to or cancelled under Section 78 is not considered a candidate at all and cannot be validly substituted in the electoral process.

2. The existence of a valid CoC is a condition sine qua non for a disqualified candidate to be validly substituted.

3. A candidate who is disqualified under Section 68 can be validly substituted pursuant to Section 77 because he remains a candidate until disqualified.

4. A person whose COC has been denied due course to and/or cancelled under Section 78 cannot be substituted because he is not considered a candidate.

5. Material misrepresentation cases are not included in Section 77 as valid grounds for candidate substitution.

6. The COMELEC's grant of the petition in SPA No. 98-019 without any qualification indeed resulted in the disqualification and cancellation of Jose "Pempe" Miranda's certificate of candidacy. The COMELEC's grant of the petition without any qualification amounted to the cancellation of the certificate of candidacy prayed for in the petition.

7. The HRET committed grave abuse of discretion in approving the substitution of the private respondent. The HRET should not have adopted the COMELEC En Banc's erroneous finding that the COMELEC First Division's resolution only speaks of disqualification and not cancellation of the certificate of candidacy. The HRET's decision was contrary to law and settled precedents.

8. The private respondent's qualification to run for public office, which was linked to her husband's qualifications, should be subject to quo warranto proceedings falling within the exclusive jurisdiction of the HRET and independent from any previous proceedings before the COMELEC.

9. The HRET gravely abused its discretion in adopting the flawed findings of the COMELEC regarding the private respondent's eligibility to run for public office.

10. The private respondent was not a bona fide candidate for the position of Representative for the Fourth District of Leyte when she ran for office.

PRINCIPLES:

• A proceeding under Section 78 of the Omnibus Election Code (OEC) is similar to a quo warranto proceeding under Section 253 of the OEC in that they both deal with the eligibility or qualification of a candidate.

• The deliberateness of the misrepresentation or intent to defraud is of little consequence in a Section 78 petition; what matters is that the person's declaration of a material qualification in the CoC is false.

• A person whose CoC had been denied due course to or cancelled under Section 78 is not treated as a candidate at all and is deemed to have never filed a CoC.

• A CoC formalizes a person's public declaration to run for office and evidences his or her statutory eligibility to be elected; without a valid CoC, one is not considered a candidate under legal contemplation.

• In order for candidate substitution to take place under Section 77 of the OEC, there must be a validly filed CoC by an official candidate of a registered or accredited political party.

• The existence of a valid CoC is a condition sine qua non for a disqualified candidate to be validly substituted.

• A candidate remains a candidate until disqualified under Section 68.

• Denial of due course to and/or cancellation of a COC under Section 78 means that the person is not considered a candidate.

• Substitution of candidates is only applicable when the official candidate dies, withdraws, or is disqualified for any cause as provided in Section 77.

• Material misrepresentation cases are not valid grounds for candidate substitution under Section 77.

• Grave abuse of discretion arises when a lower court or tribunal patently violates the Constitution, the law, or existing jurisprudence.

• The HRET, as the "sole judge" of all contests relating to the election, returns, and qualifications of the members of the House, may be subject to the Court's jurisdiction to check for grave abuse of discretion.

• The HRET is not bound by previous COMELEC pronouncements regarding the qualifications of members of the House of Representatives. The HRET's jurisdiction cannot be circumvented or rendered nugatory by COMELEC resolutions.

• The term "qualifications" in relation to election, returns, and qualifications refers to all matters affecting the validity of the contestee's title, including his eligibility and the adequacy of his certificate of candidacy.

• The HRET's jurisdiction is exclusive and independent from the COMELEC in determining qualifications to run for public office.

• The Court retains certiorari jurisdiction over the HRET to check whether it has gravely abused its discretion.

• The Court upholds the Constitution and the laws through the exercise of its power of judicial review.