Facts:

Petitioners sought for respondent Poes disqualification in the

presidential elections for having allegedly misrepresented
material facts in his (Poes) certificate of candidacy by claiming
that he is a natural Filipino citizen despite his parents both being
foreigners. Comelec dismissed the petition, holding that Poe was
a Filipino Citizen. Petitioners assail the jurisdiction of the Comelec,
contending that only the Supreme Court may resolve the basic
issue on the case under Article VII, Section 4, paragraph 7, of the
1987 Constitution.
Issue:
Whether or not it is the Supreme Court which had jurisdiction.
Whether or not Comelec committed grave abuse of discretion in
holding that Poe was a Filipino citizen.
Ruling:
1.) The Supreme Court had no jurisdiction on questions regarding
qualification of a candidate for the presidency or vicepresidency before the elections are held.
"Rules of the Presidential Electoral Tribunal" in connection
with Section 4, paragraph 7, of the 1987 Constitution, refers to
contests relating to the election, returns and qualifications of
the "President" or "Vice-President", of the Philippines which the
Supreme Court may take cognizance, and not of "candidates" for
President or Vice-President before the elections.
2.) Comelec committed no grave abuse of discretion in holding Poe
as a Filipino Citizen.
The 1935 Constitution on Citizenship, the prevailing fundamental
law on respondents birth, provided that among the citizens of the
Philippines are "those whose fathers are citizens of the
Philippines."
Tracing respondents paternal lineage, his grandfather Lorenzo, as
evidenced by the latters death certificate was identified as a
Filipino Citizen. His citizenship was also drawn from the
presumption that having died in 1954 at the age of 84, Lorenzo
would have been born in 1870. In the absence of any other
evidence, Lorenzos place of residence upon his death in 1954

was presumed to be the place of residence prior his death, such

that Lorenzo Pou would have benefited from the "en masse
Filipinization" that the Philippine Bill had effected in 1902. Being
so, Lorenzos citizenship would have extended to his son, Allan--respondents father.
Respondent, having been acknowledged as Allans son to Bessie,
though an American citizen, was a Filipino citizen by virtue of
paternal filiation as evidenced by the respondents birth
certificate. The 1935 Constitution on citizenship did not make a
distinction on the legitimacy or illegitimacy of the child, thus, the
allegation of bigamous marriage and the allegation that
respondent was born only before the assailed marriage had no
bearing on respondents citizenship in view of the established
paternal filiation evidenced by the public documents presented.
But while the totality of the evidence may not establish
conclusively that respondent FPJ is a natural-born citizen of the
Philippines, the evidence on hand still would preponderate in his
favor enough to hold that he cannot be held guilty of having
made a material misrepresentation in his certificate of candidacy
in violation of Section 78, in relation to Section 74 of the Omnibus
Election Code.