MANILA, Philippines — The Supreme Court has abandoned the “second placer” rule in local elections, ruling that a candidate who received the second-highest number of votes has no right to assume an elective post after the leading candidate is disqualified.
The En Banc, during its Aug. 26, 2026 session, denied with finality the motion for reconsideration filed by Datu Pax Ali S. Mangudadatu in G.R. Nos. 260219 and 260231, affirming its ruling canceling his certificate of candidacy for governor of Sultan Kudarat.
The Court held that when an elected candidate is subsequently found ineligible to hold office, the resulting permanent vacancy must be filled under the succession provisions of the Local Government Code—not by proclaiming the second placer as the winner.
For local governorships, this means the vice governor succeeds to the position and serves the remainder of the term.
The ruling effectively rejects the practice known as the “second placer rule,” under which the candidate who finished second is declared the winner after the top vote-getter is disqualified.
The Court stresses that no law authorizes such a rule.
