27/08/2026
The ๐๐ฏ ๐๐ข๐ฏ๐ค, during its session on August 26, 2026, acted on G.R. Nos. 260219 and 260231, ๐๐ข๐ต๐ถ ๐๐ข๐น ๐๐ญ๐ช ๐. ๐๐ข๐ฏ๐จ๐ถ๐ฅ๐ข๐ฅ๐ข๐ต๐ถ ๐ท. ๐๐ฉ๐ฆ ๐๐ฐ๐ฎ๐ฎ๐ช๐ด๐ด๐ช๐ฐ๐ฏ ๐ฐ๐ฏ ๐๐ญ๐ฆ๐ค๐ต๐ช๐ฐ๐ฏ๐ด, ๐๐ฉ๐ข๐ณ๐ช๐ง๐ข ๐๐ฌ๐ฆ๐ฆ๐ญ ๐๐ข๐ฏ๐จ๐ถ๐ฅ๐ข๐ฅ๐ข๐ต๐ถ, ๐๐ป๐ฆ๐ญ ๐. ๐๐ข๐ฏ๐จ๐ถ๐ฅ๐ข๐ฅ๐ข๐ต๐ถ, ๐ข๐ฏ๐ฅ ๐๐ข๐ช ๐๐ญ๐ช ๐. ๐๐ฏ๐ต๐ฐ๐ฏ๐จ, by denying with finality the motion for reconsideration filed by Datu Pax Ali S. Mangudadatu, affirming its earlier ruling that upheld the cancellation of his certificate of candidacy for Governor of Sultan Kudarat and abandoned the โsecond placer rule.โ
The SC held that the resulting vacancy should be filled by the Vice-Governor.
The โsecond placer ruleโ refers to the practice of declaring the candidate who received the second highest number of votes as the winner after the candidate with the highest number of votes is later found disqualified or ineligible.
Mangudadatu, in his motion, insisted that the second placer rule has clear basis in law and should not be abandoned.
The SC reiterated that no law authorizes the second placer rule. It emphasized that the ๐๐ฐ๐ฏ๐ด๐ต๐ช๐ต๐ถ๐ต๐ช๐ฐ๐ฏ recognizes as elected only the candidate who received the highest number of votes.
The SC explained that when the winning candidate is later found ineligible to hold office, a permanent vacancy arises. For local elective positions covered by the ๐๐ฐ๐ค๐ข๐ญ ๐๐ฐ๐ท๐ฆ๐ณ๐ฏ๐ฎ๐ฆ๐ฏ๐ต ๐๐ฐ๐ฅ๐ฆ (LGC), that vacancy is filled through the rule on succession, not by proclaiming the second placer as the winner. Accordingly, the Vice-Governor succeeds to the position of Governor for the remainder of the term.
The SC clarified that its ruling is limited to local elective positions covered by the LGC. The case did not address the application or non-application of the second placer rule or succession rules for national elective positions, as these issues were not raised before the Court.
However, the SC stressed that succession for national elective positions like the President and Vice-President is governed exclusively by Article VII, Sections 7 and 8 of the ๐๐ฐ๐ฏ๐ด๐ต๐ช๐ต๐ถ๐ต๐ช๐ฐ๐ฏ, which prescribe the order of succession when the President or Vice-President fails to qualify, dies, or is permanently disabled, removed from office, or resigns.
The SC also clarified that its ruling applies to pending cases, emphasizing that second placers have no vested right or entitlement to be declared the winner.
The full text of the August 26, 2026 Resolution in G.R. Nos. 260219 and 260231 will be uploaded to the Supreme Court website once available.
