The Supreme Court has abandoned the "second placer rule" in election cases where the winning candidate is disqualified, stating it has no legal basis.
Instead, the Court ruled that succession rules under the Local Government Code (RA 7160) must be followed for permanent vacancies resulting from disqualification.
This decision was made in an en banc ruling promulgated on April 22, 2025, penned by Associate Justice Samuel Gaerlan.
The ruling abandons the precedent set by Jalosjos Jr. vs. Comelec in 2012.
The case originated from a petition filed by Datu Pax Ali Mangudadatu, who won the Sultan Kudarat gubernatorial elections but had his certificate of candidacy cancelled by the Comelec.
The Supreme Court emphasized that proclaiming the second placer in post-election disqualification cases undermines the electorate's choice and contradicts the Constitution.
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