27/08/2026
May nagtanong lang sakin kanina, sinagot agad ng Supreme Court ☺️
The 𝘌𝘯 𝘉𝘢𝘯𝘤, during its session on August 26, 2026, acted on G.R. Nos. 260219 and 260231, 𝘋𝘢𝘵𝘶 𝘗𝘢𝘹 𝘈𝘭𝘪 𝘚. 𝘔𝘢𝘯𝘨𝘶𝘥𝘢𝘥𝘢𝘵𝘶 𝘷. 𝘛𝘩𝘦 𝘊𝘰𝘮𝘮𝘪𝘴𝘴𝘪𝘰𝘯 𝘰𝘯 𝘌𝘭𝘦𝘤𝘵𝘪𝘰𝘯𝘴, 𝘚𝘩𝘢𝘳𝘪𝘧𝘢 𝘈𝘬𝘦𝘦𝘭 𝘔𝘢𝘯𝘨𝘶𝘥𝘢𝘥𝘢𝘵𝘶, 𝘈𝘻𝘦𝘭 𝘝. 𝘔𝘢𝘯𝘨𝘶𝘥𝘢𝘥𝘢𝘵𝘶, 𝘢𝘯𝘥 𝘉𝘢𝘪 𝘈𝘭𝘪 𝘈. 𝘜𝘯𝘵𝘰𝘯𝘨, 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 “second placer rule.”
The SC held that the resulting vacancy should be filled by the Vice-Governor.
The “second placer rule” 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 𝘊𝘰𝘯𝘴𝘵𝘪𝘵𝘶𝘵𝘪𝘰𝘯 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 𝘓𝘰𝘤𝘢𝘭 𝘎𝘰𝘷𝘦𝘳𝘯𝘮𝘦𝘯𝘵 𝘊𝘰𝘥𝘦 (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 𝘊𝘰𝘯𝘴𝘵𝘪𝘵𝘶𝘵𝘪𝘰𝘯, 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.
Read the full text of the Press Briefer at https://sc.judiciary.gov.ph/?p=171947.
Read the full text of the SC’s April 25, 2025 Decision in G.R. Nos. 260219 and 260231 at http://sc.judiciary.gov.ph/?p=146486.
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