EPISODE 76: Philippine Elections – Residency Requirement and Second Placer Rule

Welcome to the Supreme Court Podcast. All opinions expressed in this podcast do not reflect the views of the Supreme Court. For clarity, the text of the decision prevails. What happens when the winning candidate's certificate of candidacy is cancelled due to false material representation? Who should take over? In the May 2022 National Local Elections, Datu Paks Ali Esmangudadatu, then the incumbent mayor of the Municipality of Datu Abdala Sangki Maginna Nau, ran and won in the Sultan Kudarat gubernatorial race. However, even prior to the elections, two petitions had been filed challenging his COC. Both questioned the truthfulness of his claims that he was a resident of Porok Garden Tamna Lothayan Sultan Kudarat, and that he had lived there for one year and eight months before the May 9, 2022 elections. The petition said Paks Ali had continued to serve as mayor of Datu Abdala Sangki Maginna Nau, and therefore had not abandoned his residence in the province of Maginna Nau. On January 18, 2022, the Common Lake First Division issued a resolution, canceling the COC of Paks Ali first failure to comply with the residency requirement. Considering that when Paks Ali filed his candidacy, he was incumbent mayor of Datu Abdala Sangki Maginna Nau, the Common Lake First Division held that Paks Ali violated Section 78 of the omnibus election code when he committed a false representation in his COC on a material fact, which is a grant for the cancellation of his COC. His ruling was affirmed by the Common Lake on Bank, prompting him to bring the case to the Supreme Court. In its decision promulgated in April 22, 2025, the Supreme Court on Bank resolved two issues. First, does the incumbency and continue with discharge of duties of public officials in one locality preclude them from validly acquiring a new domicile in another locality, so as to satisfy the residency requirement under the local government code? More importantly, the Supreme Court revisited the second-place rule to determine who should serve the remaining term of Paks Ali, as his qualification was appelled by the Supreme Court. Hi, I'm attorney Mike Navalia, Supreme Court Chief Communications Officer. It's the 4th of July 2025, and today we talk about several very important issues in any election. The concept of domicile, false material representation, and the certificate of candidacy is a ground for cancellation of the COC, and the second-place rule, which up until the ruling that we will be discussing today, had allowed the second-place to take over in case the winner's COC is canceled. We discussed this issue within the context of Tato Paks Ali Esmogudadato, versus the Commission on Elections at Al. G are numbers 2-6-0-19 and 2-6-0-231, penned by Supreme Court Associate Justice Samuel H. Garland, and decided by the Court on Bank on April 22, 2025. Joining us to talk about this case is Philippine Judicial Academy Lecturer and former Commonly Commissioner, Attorney Louis Tito F. G. F. Commissioner Louis, welcome back to the Supreme Court podcast. I'd say pleasure and honor to be here, Thornie Mike. All right, come to me. This is a very interesting case. The voting of the Supreme Court is very close. Seven to six to declare that there was false material representation, while eight to five to abandon the second-place rule. We will discuss this later on, but just to start the discussion, talk to us about the false material representation rule as a ground to deny due course or cancel the certificate of candidacy of a candidate under Section 78 of the omnibus election code. When is there false material representation in which entries in the Certificate of Candidacy are considered material? Okay, first and foremost, one cannot be voted on unless he or she files his Certificate of Candidacy. So what should be reflected therein? Well, in the Certificate of Candidacy, the requirements for eligibility of the candidate to the position he is seeking election two should be there. And Section 78 of the omnibus election code says that the representation as to the eligibility of the candidate should be truthful. So if it's false, then that will give rise to what is called false representation of a material fact. The material facts are those that relates to the eligibility of the candidate, for example, residents, age, citizenship and the fact of being a registered voter in the constituency where the candidate is seeking to be elected. All right, and there are also other grounds that may be raised as a basis for saying that a candidate may have committed false representation of a material fact, for instance, if one is a dual citizen and under the local government code, a dual citizen cannot be a candidate and therefore he cannot also be eligible to the effectively eligible to the position he's seeking to be elected to. Then an EP says he is not a dual citizen. Then that is a false representation of a material fact as well. And if I recall correctly, Commissioner Luffy, you can even commit to offenses first by being ineligible and second by checking that box, tiny box in the certificate of the C which is the I am eligible, despite the fact that you are not. There is a question there other than the information that needs to be put in the certificate, which as the person accomplishing the certificate, if he is eligible to the office he's seeking to be elected to. And if he says yes, of course he will say yes, and it turns out to be false, then that would already be a ground to cancel the certificate of candidacy because of a false material representation. And of particular interest to our discussion today, Commissioner Luffy is the concept of residence. And I understand that in election cases, we usually interchange the use of domicile with the concept of residence. And he explained us briefly what domicile entails. Well, domicile means not only the bodily presence of a person in a certain locality, there should be an intent of that person to stay there permanently, or maybe until he dies. Okay, so that should be the intention. And then if someone changes domicile, then he would have to have a bodily presence in the new domicile. He must also intend to stay in the new domicile permanently. And he must also evince or show his intent to abandon the previous domicile. So ensure there are three elements to the concept of domicile. Now in the case of Pax Ali, the allegation was that he misrepresented his place of residence. He claimed that he was living in Sultan Qudrat. But he continued to serve as mayor in a town in Maginna now. That's at least until November 2021. Why was the place of residence material in this particular place? Well, under the local government code, to be eligible to serve as a local government official in a constituency, and let's say in this case, in a province, one has to be a resident of the province. Well, being mayor of that Abdullah Sankey, which is in Maginna now, is not in Sultan Qudrat. So we cannot be considered to be a resident of a Sultan Qudrat because to be a mayor in that Abdullah Sankey Maginna, you should be a domicile. Your domicile should be in that municipality. In Maginna now, it's just a different province. And in fact, he transferred his domicile from his domicile origin in Sultan Qudrat. Two, that Abdullah Sankey in Maginna now. Just to be able to run. Just to be able to become a mayor. To become a mayor. No, in this case, that Pax Ali was saying he had been incrementally moving his domicile to his new residence in Sultan Qudrat. He presented proof as to his physical presence. Walk us through the argument that he cited. I believe he also cited some cases. For instance, Turaino, Mitra and Sabili versus Komelik, to claim that his incomemen see as mayor of that of Abdullah Sankey did not preclude him from acquiring domicile in Sultan Qudrat. Well, what he is precisely saying is that, you know, the issue in this case is his residence in Sultan Qudrat because that is the position that he was aspiring for at that time when the case was initiated. The fact of his being a mayor, he said, should not affect his transfer of domicile from Maginna now to Sultan Qudrat. And he cited the case of Turaino versus Komelik. Turaino is actually a case involving then governor or emano. Well, he cited the case of Turaino versus Komelik involving 'Begobernor' o misamis oriental, 'Who decided to run for mayor in Kagayang di Oro City?' 'Well, Kagayang di Oro City is a highly urbanized city whose voters do not vote for governor of misamis oriental.' 'Now, he was allowed to run for mayor in Kagayang di Oro City because he was actually a resident of Kagayang di Oro. And then when he was a 'Gobernor' of misamis oriental, in the case of Mitra. Okay, this has something to do with Mitra who was then the incumbent member of the House of Representative, representing the district of Puerto Princesa and Aborland used to belong. He was a resident of Puerto Princesa and now he transferred his residents to Aborland, Palawan. And because he needed to do that, well, that was his thinking because Puerto Princesa was just converted into a highly urbanized city again. And his voters cannot vote for governor. He was already intending to run for governor at that time. And he was also allowed to run for governor and recognize his transfer to Aborland from Puerto Princesa as a valid transfer of domicile. So that was his argument. That was in these cases of Torino and Mitra. The transfer was allowed. So should his transfer be recognized by. That is his argument. By Comelik and several justices agreed with Paxali, you have justices Ramon Pol Hernando and Amilazor, for instance, comparing his case to that of Mitra. But the majority of the court did not seem to buy that argument. They said that he was mistaken in relying on these cases. How did the majority explain that? What's the difference between the Mitra and Torino cases from the case of that of Paxali? Well, the majority thought that the circumstances in the case of Torino and Mitra are different because geographically, for instance, in the case of Torino, Kageyandi Oro is in Misami's oriental. So he did not change his. Domicile. Domicile in the way. Yes, Domicile anyway. And in the case of Mitra, it's the same thing. He would be representing the same district actually. So there is really no practical reason to distinguish their Domicile. So that should not matter. That should not matter. And like in the case of that of Paxali. Here you have two provinces. So remember, he was running for governor of Sultankodarat, but his previous residence was. Or he says Domicile was Maginda now. So Magkaibayong Provincia. And did it matter, Komliwi, that Paxali was raised in his ancestral house in Sultankodarat, the family's ancestral house? Because Justice Josep Lopez said in his dissenting opinion, Domicile once lost can easily be regained. And according to Justice Lopez, he showed some manifestations that he was really intending to go back to the original Domicile, which is in Sultankodarat. How did the majority address this point? Well, first and foremost, the majority are considered that he has bodily presence and residence in Sultankodarat. Okay, that's clear. But the question is, did Maginda Dato have his intent to stay in Sultankodarat, permanently and abandon his previous Domicile in. So one thing more is that the majority cited the fact that in his pleadings, Maginda Dato even admitted that he indeed transferred his Domicile. And that's why his word was to reestablish his Domicile in Sultankodarat. So if you say you reestablish, then it means there's an admission that you lost your Domicile. That Domicile. And then you want to reestablish it. And the fact that he was a mayor of Dato Abdul-Sankhi and did not resign, supposedly at the time that he supposedly have shown his intent to go back to Sultankodarat. Sultankodarat. Did not show any intent of him staying in Sultankodarat, abandoning his previous Domicile in Maginda now. Although the decision did acknowledge that he resigned as mayor of Dato Abdul-Sankhi Maginda now, but only in November of 2021. And the court said this was a mere afterthought because you already have two petitions filed against you after you filed your certificate of candidacy. So why did the court say that this is proof of misrepresentation, that this was deliberate? Because when he filed a certificate of candidacy, he was still performing the function of to pay you remember when he resigned, it was after he filed a certificate of candidacy and in fact, it was after a petition or two petitions were filed against him. So he knew all along that he was not a domicile of Sultankodarat. And that's why he needed to resign to show and to perfect his claim that he had already transferred his Domicile to Sultankodarat from Maginda now. Assuming that we base it from November 2021, would the period between November 2021 and May 2022 have been enough for him to establish it? It wouldn't be enough because that would be less than one year from the day of the election that will be barely five months. Yes. So he would not be qualified or he would not be eligible on the issue on the matter of residents. And this brings us back to the main question that was answered in the decision. Does an elected officials' incompetency and continuous discharge of his or her duties in a different locality preclude him or her from validly acquiring a new domicile choice in another locality for the purpose of the local government code's residency requirement? You have Justice Ben Kaguya saying in his opinion that you can actually change but you risk your residency being questioned and since residency is a continuing requirement, you actually risk losing that particular incumbent post. But what did the majority say about this? How did the Supreme Court, at least the majority in this case, decide this issue? Well, the majority said it's not in effect. It said that it's not basically, it's not really conceptual. It's not the fac of incongruency. But the lack of intent manifested by his remaining to be a mayor or his continued performance of the function of a mayor in a locality located in a province different from that he was running for. So that's how the Supreme Court, majority decision saw the circumcissance. So in effect, is the Supreme Court saying that when you are in incumbent, you cannot claim that you are establishing another domicile in another province, especially if they are geographically apart. They're not within the same geographic area, unlike in the case of Torino and Mitra, where the new supposed domicile is within the same province. So the solution for that would be if you're a current mayor of one municipality in a province, and you want to run in another province, you should resign. Well, that is the implication of the majority decision, because what was continually emphasized in this decision is that the eligibility of a local or an elected public official should continue not only at the time that when he was elected, but during the entirety of the term of office. Right. And with the disqualification of Pax Ali commissioner Louis and the cancellation of a certificate of candidacy, the next question would be who would fill up the vacancy and serve the remainder of his term. Before we go into that, can you give us a discussion first on the prevailing rule when it comes to cases where the COC is cancelled or deny due course up until this case. What was the prevailing rule? The prevailing rule which actually started in the case of Hallowshawz versus Komelek, which was promulgated in 2012, said that if the ground for the material misrepresentation, then that would mean that the certificate of candidacy is void of the initials. So it never had any effect. So the candidate who accomplished a certificate of candidacy that is void, that be an issue, has is never a candidate. It is not a candidate, according to the Omnibus election code, the rules on appreciation, a vote for a non-candidate will have the will be considered straight. Okay, so well I'm voto. There's no it's not counted. It's not counted. So if that candidate turns out to obtain the highest number of votes in situation where Kamilek was not able to resolve the case with finality before election, then it is as if that the vote that that candidate obtained is it becomes, you know, encountered or straight. Not counted. I mean, so he's no longer the first place. The second place becomes the first place. So that's the second place a rule. That's the second place. So meaning that's the candidate, the qualified candidate with the highest votes. The qualified candidate with the highest vote. Rule and that is what one of the separate opinions started just in Hallowshawks in 2012, at least according to the rule. Well, there were two cases that adopted that rule sometime in the 80s, but that consistent it has been the rule on success and that has prevailed until 2012. So now so before 2012, it was the rule on succession. Yes, right. Well, talk to us a bit more about the rule and succession. Well, rule on succession can only come about at the start of the term of office, of course, because there will be no vacant succession can only set in when there's vacancy. Right. Okay, there can only be vacancy when at the time when the term starts and there's no one to occupy the office. Right. Okay, in this case, when the one who obtained the highest number vote is not qualified, then there is a failure to qualify. Right. Okay, if there's a failure to qualify, I think the local government, as local government called, as pointed out in the majority decision, is clear. It should be the elected vice mayor or vice governor. Whoever the local government designates as a successor to the to the to the one who was disqualified would now become occupied the position. So now the rule that's the rule on succession. Right. So in this case, a commissioner, Louis, eight members of the court, including Chief Justice Alexander Gismundo, Associate Justice Alfredo Benjamin Kaguya, Rodil Zalameda, Samuel Garilano, is the punente here, Ricardo Rosario, José Mides Marquez, Antonio Cujunio and Maria Filomena Singh, they all voted to apply the rules on succession under section 44 of the local government code. And the majority abandoned the second place rule for lack of legal basis and for being inconsistent with the essence of republican SM. Why did the Supreme Court say there's a need to revisit the second place rule? Can you expound on the reasoning for abandoning a rule which has been in place for over a decade? Well, the Supreme Court cited the fact and which was the previous argument or reason that prior to 2012 was the reason, you know, reasoning of the Supreme Court coming up with decision in similar cases is that once a person is not elected, meaning he is not the one who obtained the majority of the vote's cash, then he's not elected. And someone who's not elected was rejected by the people who you cannot have someone occupy a public office if he has been rejected by the people. So that's the principle logic of the majority decision. So a second place is a loser. He can never be a winner. So that's the implication of the decision of the majority here. That is so then no one is elected. So there is a failure to qualify on the part of the person who obtained the highest number of vote. There's a failure to qualify. Then the local government called set in who would then become the governor in this case. This doctrine of rejection of the second place or according to at least Justice Mancaywa is supported by law and public policy. What was their basis for saying this is supported by law and public policy? Well, first and foremost, it's a principle of republicanism, principle of democracy. According to the Supreme Court, they say that as I've said, candidates have been rejected conceptually cannot rule because he was rejected. Now, and there have been, as you mentioned earlier, inconsistent applications of this rule up until 2012. And now you have five members of the court, senior associate Justice Marvick Leonan, associate justice is Ramon Pol Hernando, Amil Azaro Javier, Mario Lopez and Jose Plópez. They voted against abandoning the second place or rule. Now, for the purpose of discussion only, just so that we can understand why they oppose that. What points did they race against abandoning the second place or rule? Well, the fact that a certificate of candidacy of a candidate who made false representation or who is not qualified under section 40 of the omnibus election code or section 40 of the local government code and section 12 of the omnibus election code means that there, if the ground for disqualification existed at the time of the filing of the certificate of candidacy, then the certificate candidate is void. If the certificate candidate is void, then there is no candidate in the first place. So you cannot vote for an un-candidate. So those votes, they may have obtained are considered invalid votes. You cannot count them. So technically, the first place is the one who came next. The qualified one. So that is also according to them, that is consistent with the republicanism. You have the one who obtained the highest valid votes cast in an election. And just as Jose Plópez also pointed out that if you were to allow the next in line under the rule of succession to take the post that was vacant, you would actually ignore the fact that people voted for that person for a different position, not for the position which was vacant. That's the point of Jose Plópez. But ultimately, what is the rule that the Supreme Court decided on in this majority decision? And how does it apply now? I mean, if this decision were to be affirmed in a proper motion for reconsideration, for example, what is the rule now that the Supreme Court decided on at least with respect to this case? It would mean therefore that the second place, the so-called second-place would no longer have a chance to be occupying the office contested, the contested office because he did not win the elections. And someone who did not win the election cannot be a public servant, cannot occupy the public office. So that rule would have to be followed out if this case becomes final. So there's no more distinction as to the course of the disqualification or cancellation of the COC. As long as the seat is vacant, the rule of succession applies. Yes. Regardless of the proceeding, regardless of the situation. That seems to be the implication of the Supreme Court decision. And of course, this is not yet final because it can still be subject to motion for reconsideration. So when will this be implemented? Well, after the motion for reconsideration, there's one file is decided. And then that would, of course, make the decision final and executed. That would therefore define the rules that would be in a situation that can happen henceforth. And would you consider this a landmark ruling, Komluvi? I mean, you serve in the communique for the full term. So you've probably gone through similar cases like this one. How significant a change in terms of a doctrine is this operationally? What what communique will do is it will no longer proclaim the second place. Then it would just have to you know, leave it at that until the time that the term of office starts. And then if there's no one, you know, occupying the office and obviously there will be no one if the one obtained the I is number of vote is disqualified or is declared or if there's a material material misrepresentation, then the rule on success should come. And that would already be something that you know, the ILG should be monitoring instead of covelec. All right. Very, very interesting. And I learned a lot from this discussion today, Komluvi. And a final, final word from you, perhaps what's the key takeaway from this case of Datopaks Ali Mangudadato that perhaps not only those who intend to run or politicians should keep in mind, but voters as well. First, I would like to look at the burden that is imposed on communique to really make their decision or its decision way before the the election, that would have, you know, resolved all issues regarding this. So it's when a case, a disqualification case or a material representation case is decided way before, then it's clear that, you know, the one who was disqualified or who certificate to candidacy was canceled would not already, would not anymore become a candidate. So that would have cleared the math. So I think that's the most important thing. And for voters, I am, you know, be discerning probably. I mean, know the qualification or the eligibility of the candidates you're voting for. So that you cannot, you will not waste your votes. Speak. All right. On that note, thank you so much. Commissioner Louis for joining us today. Thank you. Thank you. My pleasure. To our listeners, if you wish to read the full text of the decision of the Supreme Court, please visit the Supreme Court website at c.judishary.gov.ph and search for gr numbers 260-219 and 260-231. Datopaks Ali Esmagudadatu versus the Commission on Elections et al. Here's Tefat Inidobaltran, Supreme Court Information Officer for recent updates about the court. From the Supreme Court of the Philippines, here's the latest. The Supreme Court on back during its session on July 1, 2025 issued a writ of Cali-Kasan in a case which seeks to stop the construction of the Samal Island Davos City Connector Bridge project. The writ was issued against the Department of Public Works in Highways, Department of Environment and Natural Resources, Samal Island Protected Landscape and Seascape Protected Area Management Board, and China Road and Bridge Corporation. Petitioners Carmella Marie Santos, Mark Benelbear and Sustainable Davo Movement, claimed that the project will cause actual, serious and irreversible damage to coral reefs in Paradise Reef Samal Island and Heezan Marine Protected Area in Davos City. The court required the respondents to file a verified return on the petition within 10 days. It also referred the prayer for the issuance of a temporary environmental protection order to the Court of Appeals Kagan the Oral Station for Action. The Supreme Court has ruled that a child's rape by her adoptive uncle does not warrant a harsher penalty because they are not related, based on the prevailing law at the time the crime was committed. In a decision written by Associate Justice Jepardem Ambao, the S.E.S. Third Division found a man guilty of raping his 10-year-old adoptive niece, but ruled that his penalty cannot be increased by the qualifying circumstance of relationship. The S.E. appealed accused's conviction, but declared him guilty of statutory rape instead. The S.E.S. clarified that at the time the rape was committed, the existing laws on adoption did not consider the victim to be related to her adoptive parents' family. While R.A. Number 11642, or the Domestic Administrative Adoption and Alternative Child Care Act, expanded the relationship to include the adoptive parents, legitimate siblings, and legitimate descendants, it took effect only in 2022 and could not be applied to this case since the crime was committed in 2012. In another case, the S.E.S. found two managers of a pizza restaurant guilty of simple theft for having kept service charges that should have been paid to the restaurant's employees. The S.E. Second Division, through the financial associate Justice Antonio Codr Jr, sentenced two store managers at a shaky branch in Anorizal to six months in prison. It also ordered them to pay their fellow employees the with health service charges. The S.E.O. ever modified the conviction from a qualified theft to simple theft. Under the revised penal code, theft becomes a more serious crime known as qualified theft when it involves the abuse of trust or confidence. In this case, while the store managers took the service charges meant for the employees, the S.E.S. clarified that the victims were the employees, not the employer, big G-fill foods, and entertainment ink. Since there is no special trust relationship between managers and rank and file workers, there was no abuse of trust or confidence in this case that would have qualified the theft. In another decision, the S.E.S. has ruled that an acknowledgement receipt cannot be considered a contract of sale unless it clearly shows that the seller intends to transfer ownership of the property to the buyer. In a peninshia by associate Justice Maria Filamenta Singh, the S.E.S. Third Division ruled that the agreement between Verhiliy Chavez and his fellow petitioners on one hand, the spouse's Hosellito and Idriana Goppes on the other, was a contract to sell, not a contract of sale. The S.E. explained that in a contract to sell, the seller does not agree to transfer ownership of the property just yet. The seller only commits to fulfilling their promise to sell the properties and transfer title to the buyer after an event. Typically, the full payment of the purchase price. In this case, the acknowledgement receipt did not include any promise to transfer ownership. It only showed that the spouse is needed to meet certain conditions. The payment of the purchase price and preparation of the contract to sell, deed of sale and estate settlement. On Monday, the S.E.S. in partnership with the Korea International Cooperation Agency, or Khoi Ka, held a kickoff ceremony for the implementation survey of the project titled, Improving Judicial Efficiency and Accessibility by innovating Philippine courts at the Supreme Court in Manila. Chief Justice Alexander Ismundo, Senior Associate Justice Marwick MbF Leonan and Associate Justice for Woolvilleian Weva, led the ceremony, while Country Director Mr. Jong-Yong Sun led the team from the Khoi Ka. In line with the Strategic Plan for Judicial Innovations 2022-2027, the project aims to modernize Philippine court systems, to facilitate the speedy delivery of court services by leveraging the use of modern technology and to enhance the transparency, security and efficiency of court processes in the Philippine Judicial System. Target outputs of the project include an electronic verification system and a case record management system, capacity training of personnel for digital transformation and digitization of court records. In a special session on Tuesday, integrated bar of the Philippine's officers and board of governors took their oath before the Supreme Court on bank at the Session Hall in Manila. Associate Justice Ramon Paul Hernandez administered the oath of office to IBP National President Attorney Alan Panolong. Associate Justice Henry John Paul Inting swore in IBP Executive Vice President Attorney Randall Tabayo-Yong, while Associate Justice Josep Lopez led the oath-taking of the 27th Board of Governors. Meanwhile, on July 2, 2025, the Office of the Court Administrator or OCA held a turnover ceremony of the guide to the OCA Circulars issued from 2022-2024 at the Supreme Court in Manila. Former Court Administrator and current SESOC Justice for Wool Villain-Weaba and OCA Officer in charge Assistant Court Administrator Lillian Barabalco led the event and turned over copies to the judges present. OCA Circulars are also uploaded on the OCA website, OCA.Tradishiary.gov.ph. Finally, on Wednesday, Associate Justice Raul Villain-Weaba in Court for Pills Associate Justice Jose Lorenzo de La Rosa held a ceremonial signing of the deed of donation to the Court of a parcel of land in Publishon Pila Laguna at the Supreme Court in Manila. The 1550 square meter property denoted by Justice de La Rosa will be used for the construction of the Pila Laguna Hall of Justice. Justice Villain-Weaba, then the Court Administrator, served as the signatory on behalf of the Court during a signing held earlier in March. Assistant Court Administrator Lillian Barabalco, Officer in charge of the Office of the Court Administrator, was also present during the ceremonial signing. You are now up to date with a Philippine Supreme Court. I am Daphat Indi-Diblatran, Supreme Court Information Officer. And that's our podcast this week. Join us again next time for a detailed discussion of select cases decided by the Supreme Court. I'm attorney Mike Navalio, your Supreme Court Chief Communications Officer. You can catch this podcast of the Supreme Court Public Information Office's accounts on x, facebook, instagram, youtube and Spotify. You can also catch previous editions on our website and on Spotify. This podcast episode was produced by the Supreme Court Public Information Office with attorney Karen Martinez, Jay Rampilio and May C. Balazar Searchers, Brian Austria, Don Ryan Balza, Don Enzolani, Austin Lyskade and Bay Abatungas Audio and Video Editors and Taik Flores and Jerome Batumalakes Web Editors.