Friday, October 5, 2012

Nicolas-Lewis, et al. vs COMELEC (2006) (Political Law)

Loida Nicolas-Lewis, et al. vs. COMELEC | G.R. No. 162759 | August 4, 2006

Facts: Petitioners, who reacquired Philippine citizenship under R.A. No. 9225, sought registration and certification as “overseas absentee voters” however they were advised by the Philippine Embassy in the US that as per a COMELEC letter to DFA dated September 23, 2003, they have no right yet to vote in such elections owing to their lack of the one-year residence requirement prescribed by Sec. 1, Art. IV of the Constitution.

When petitioner Nicolas-Lewis clarified on said requirement, the COMELEC replied its position that the OAVL was not enacted for the petitioners and that they are considered regular voters who have to meet the requirements of residency under the Constitution.

Faced with the prospect of not being able to vote in the May 2004 elections because of COMELEC's refusal to include them in the National Registry of Absentee Voters, petitioners filed on April 1, 2004 a petition for certiorari and mandamus.

On April 30, 2004 (a little over a week before Election Day), COMELEC filed a Comment praying for the denial of the petition. Consequently, petitioners were not able to register let alone vote in said elections.

On May 20, 2004, the OSG filed a Manifestation (in Lieu of Comment) stating that “all qualified overseas Filipinos, including dual citizens who care to exercise the right of suffrage, may do so,” observing, however, that the conclusion of the 2004 elections had rendered the petition moot and academic.

Issue: Must the Supreme Court still resolve said petition considering that under the circumstances the same has already been rendered moot and academic?

Held: The holding of the 2004 elections had indeed rendered the petition moot and academic, but only insofar as petitioners’ participation in such political exercise is concerned. The broader and transcendental issue tendered in the petition is the propriety of allowing dual citizens to participate and vote as absentee voter in future elections, which however, remains unresolved.

The issues are thus reduced to the question of whether or not petitioners and others who might have meanwhile retained and/or reacquired Philippine citizenship pursuant to R.A. 9225 may vote as absentee voter under R.A. 9189.

[Ruling on the main issue: Considering the unison intent of the Constitution and R.A. 9189 and the expansion of the scope of that law with the passage of R.A. 9225, the irresistible conclusion is that dual citizens may now exercise the right of suffrage thru the absentee voting scheme and as overseas absentee voters. 

The Court granted the instant petition and held that those who retain or re‑acquire Philippine citizenship under R.A. No. 9225 may exercise the right to vote under the system of absentee voting in R.A. No. 9189, the Overseas Absentee Voting Act of 2003.]

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