The Supreme Court has granted the petition of Susan Areno Yap-Sulit and declared her eligible to be elected Mayor of Tarlac City, annulling and setting aside the Commission on Elections (COMELEC) En Banc Resolution dated October 22, 2025 that had found her not qualified to run for the post.
The Court upheld Yap-Sulit's proclamation as Mayor and made permanent the Status Quo Ante Order dated November 4, 2025.
The Case
Yap-Sulit ran for and was proclaimed mayor of Tarlac City in the May 12, 2025 National and Local Elections (2025 NLE). At the time she filed her Certificate of Candidacy (COC) on October 5, 2024, she was on her third term as governor of the Province of Tarlac. She stated in her COC that she is a resident of Immaculate Concepcion Subdivision, Barangay Tibag, Tarlac City.
Amado S. De Leon and Jay-Ar Capulong Navarro, registered voters of Tarlac City, filed a Petition for Disqualification against Yap-Sulit, docketed as SPA No. 25-026 (DC). Navarro is also the incumbent punong barangay of Tibag. They alleged that Yap-Sulit failed to prove that she is a resident of Tarlac City at least one year before the 2025 NLE, and submitted several Sinumpaang Salaysay executed by barangay officials who testified that Yap-Sulit is not a resident of Barangay Tibag. They also claimed that the address she gave pertained not to a house, but to a warehouse where rice and other items were being repacked.
In her Verified Answer, Yap-Sulit claimed that she is a resident of Tarlac City, having transferred to Barangay Tibag in 2013 from Barangay Mababanaba, Municipality of San Jose, Province of Tarlac. Her application to transfer her voting registration was approved on October 23, 2014. She presented identification cards, police clearances, a joint affidavit from Tibag residents, sworn statements from two former punong barangay of Tibag, and photographs showing that the structure contained normal household fixtures, such as bed and living rooms, as well as her personal belongings.
The Issue
The question was whether Yap-Sulit met the residency requirement to run for Mayor of Tarlac City — that is, whether she was a resident of Tarlac City for at least one year before the 2025 NLE.
The Ruling
The Court ruled in favor of Yap-Sulit. Its dispositive portion states: "ACCORDINGLY, the Petition is GRANTED. The Resolution dated October 22, 2025 of the Commission on Elections En Banc in SPA No. 25-026 (DC) is ANNULLED and SET ASIDE."
The Court further declared: "Petitioner Susan Areno Yap-Sulit is declared ELIGIBLE to be elected Mayor of Tarlac City. Her proclamation as such is hereby UPHELD. The Status Quo Ante Order dated November 4, 2025, is hereby MADE PERMANENT."
By the Numbers
- COC filed: October 5, 2024
- 2025 National and Local Elections: May 12, 2025
- Voting registration transfer approved: October 23, 2014
- Year of transfer to Barangay Tibag: 2013
- COMELEC Second Division Resolution: April 14, 2025
- Motion for Reconsideration filed: April 21, 2025
- COMELEC En Banc Resolution: October 22, 2025
- Status Quo Ante Order: November 4, 2025
- Terms served by Yap-Sulit as governor: three
- G.R. No. E-03037
The Court's Reasoning
The COMELEC Second Division had dismissed the Petition for Disqualification. It treated the Petition as unsigned because its verification and certification against forum shopping was signed on February 25, 2025, but the Petition states it was signed on February 26, 2025. It also held that failure to meet the residency requirement is not among the proper grounds for a Petition for Disqualification, and that a petition to cancel the COC under Section 78 of Batas Pambansa Blg. 881 is the proper remedy. Even treating the case as one to cancel the COC, it found it filed out of time, and further found the evidence of De Leon et al. to be unsubstantiated and self-serving, while Yap-Sulit's evidence substantially proved she abandoned her former domicile in San Jose and transferred to Tarlac City in 2013.
The COMELEC En Banc reversed this, disregarding the procedural issues on the different signing dates, holding the difference of one day to be inconsequential, and ruling that Yap-Sulit is not qualified to run.
In its ruling, the Supreme Court stated that it respects and upholds the will of the electorate, not despite a candidate's ineligibility but because, from the evidence presented, there is no such ineligibility.
Source: Supreme Court decision in Susan Areno Yap-Sulit v. Commission on Elections, Amado S. De Leon, and Jay-Ar Capulong Navarro, G.R. No. E-03037.
This report summarizes a public Supreme Court decision and is not legal advice.