Case Digest (G.R. No. L-4352) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Abang Lingkod Party-List v. Commission on Elections, G.R. No. 206952, decided on October 22, 2013, Abang Lingkod was registered on December 22, 2009 as a sectoral party-list representing peasant farmers and fisherfolk. It joined the May 2010 elections but failed to secure a seat. On May 31, 2012, it filed its Manifestation of Intent for the May 2013 polls. Pursuant to COMELEC Resolution No. 9513 (August 2, 2012), previously registered groups had to prove continuing compliance under Republic Act No. 7941 at summary hearings set on August 17, 31 and September 3, 2012; Abang Lingkod submitted documents on August 16, 2012. On November 7, 2012, the COMELEC En Banc cancelled its registration for lack of a demonstrable track record and proper sectoral nominees. Abang Lingkod and fifty-one others petitioned the Supreme Court, which, in Atong Paglaum (April 2, 2013), remanded these cases under revised party-list parameters. Nevertheless, on May 10, 2013, without further hearing, the C Case Digest (G.R. No. L-4352) Expanded Legal Reasoning Model
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)