Phil is a widower who works full-time and has an AGI of $35,000. He supports his 16-year-old daughter, Mariah, who lives with him in California. Phil's parents also live with him. Phil's parents always file a joint return to pay tax on their pension income, investment income, and Social Security benefits. Phil's parents' AGI is $42,321. Everyone in Phil's family is a U.S. citizen and has SSNs. This tax year, Mariah earned $10,000 working part-time. She put the $10,000 in a college savings account.

If Phil and his parents both claim Mariah as a dependent on their returns, who would be entitled to claim Mariah as a dependent based on the tie-breaker rule?