Title
Agapay ng Indigenous Peoples Rights Alliance vs. Commission on Elections
Case
G.R. No. 204591
Decision Date
Apr 16, 2013
A-IPRA's registration was canceled by COMELEC over disputes between two factions (Lota and Insigne Groups) regarding legitimate nominees. SC dismissed the petition as moot, deferring to COMELEC's authority to resolve party-list disputes.
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Case Digest (G.R. No. 204591)

Facts:

Background of A-IPRA:
Petitioner Agapay ng Indigenous Peoples Rights Alliance (A-IPRA) is a sectoral political party advocating for the recognition, protection, and promotion of the rights of indigenous peoples. It was registered and accredited by the COMELEC Second Division on January 13, 2010, in SPP Case No. 09-214 (PL). The COMELEC recognized A-IPRA's compliance with Republic Act No. 7941 (Party-List Law) and the guidelines in Ang Bagong Bayani vs. COMELEC. A-IPRA participated in the May 2010 elections but failed to secure a seat in Congress.

Change in Nominees and Officers:
On May 31, 2012, A-IPRA filed a Manifestation of Intent to Participate in the May 2013 Elections, submitting a new list of nominees and officers (Lota Group). The original group (Insigne Group) contested this, claiming that the Lota Group members were not legitimate representatives of A-IPRA, were not members of indigenous communities, and had submitted forged documents. The Insigne Group filed a Petition for Intervention, seeking to disqualify the Lota Group and be recognized as the legitimate nominees and officers.

COMELEC's Review and Resolution:
On August 2, 2012, the COMELEC en banc issued Resolution No. 9513, initiating a review of party-list groups' compliance with RA 7941 and Ang Bagong Bayani guidelines. On November 7, 2012, the COMELEC en banc issued a resolution canceling A-IPRA's registration and accreditation, citing the failure of the Lota Group to prove that the nominees were indigenous people, active members of A-IPRA, or adherents to its advocacies.

Issue:

  1. Whether the COMELEC gravely abused its discretion in issuing the November 7, 2012 Resolution canceling A-IPRA's registration and accreditation.
  2. Whether the Lota Group or the Insigne Group should be recognized as the legitimate nominees and officers of A-IPRA.

Ruling:

The Supreme Court dismissed the petition for being moot and academic. The Court held that the issue of whether the COMELEC gravely abused its discretion had already been resolved in Atong Paglaum, Inc. v. COMELEC, where the Court upheld the COMELEC's actions but remanded the cases for reevaluation based on new parameters. The Court also ruled that the determination of the legitimacy of nominees and officers of a party-list group is within the COMELEC's authority, as part of its constitutional mandate to enforce election laws.

Ratio:

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