Title
Abang Lingkod Party List vs. Commission on Elections
Case
G.R. No. 206952
Decision Date
Oct 22, 2013
ABANG LINGKOD, a peasant-fisherfolk party-list group, challenged COMELEC's cancellation of its registration. SC ruled COMELEC abused discretion, reinstated ABANG LINGKOD, citing new party-list guidelines.

Case Digest (G.R. No. L-4352)
Expanded Legal Reasoning Model

Facts:

  • Registration and Early Proceedings
    • ABANG LINGKOD, a sectoral organization representing peasant farmers and fisherfolk, registered under RA 7941 on December 22, 2009; participated in May 2010 elections but failed to secure a seat.
    • On May 31, 2012, it filed its Manifestation of Intent to join the May 2013 party-list elections. COMELEC Resolution No. 9513 (Aug 2, 2012) required all previously registered party-list groups to undergo summary evidentiary hearings, set on August 17, 31 and September 3, 2012.
  • Summary Hearing and First Cancellation
    • ABANG LINGKOD submitted documents on August 16, 2012 but did not present witnesses at the scheduled hearings.
    • By En Banc Resolution dated November 7, 2012, COMELEC cancelled its registration for failing to prove a track record in representing the marginalized and underrepresented and for allegedly submitting edited photographs.
  • Supreme Court Remand and Second COMELEC Resolution
    • In Atong Paglaum, Inc. v. COMELEC (Apr 2, 2013), the Supreme Court granted status quo ante relief and remanded party-list cases to COMELEC to apply new screening parameters.
    • On May 10, 2013, COMELEC En Banc issued the assailed Resolution reaffirming the cancellation—without further hearings—citing proximity of elections and deeming the doctored photos unlawful statements under RA 7941.

Issues:

  • Was ABANG LINGKOD denied due process when COMELEC affirmed cancellation without conducting a new summary evidentiary hearing?
  • Did COMELEC gravely abuse its discretion in cancelling ABANG LINGKOD’s registration under the party-list system?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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