Case Digest (G.R. No. 71980)
Facts:
In Atty. Victor Aguinaldo v. New Bilibid Prison (Bureau of Corrections), Atty. Victor Aguinaldo (petitioner) filed a petition for certiorari and prohibition with application for injunctive relief under Rule 65 in relation to Rule 64 of the Rules of Court, assailing COMELEC Resolution No. 9371 dated March 6, 2012, which prescribed the Rules and Regulations on Person Deprived of Liberty (PDL) Registration and Voting in connection with the May 13, 2013 elections and subsequent polls. Resolution No. 9371 defined qualified PDLs, constituted a Committee on PDL Voting, set registration and voting guidelines, designated special polling places inside jails, and created Special Boards of Election Inspectors. Petitioner contended that the resolution lacked its own implementing rules, did not undergo public consultation, violated the equal protection clause by privileging certain detainees, and contained logistical gaps. He prayed that the Court enjoin respondents—including the Commission oCase Digest (G.R. No. 71980)
Facts:
- Promulgation of COMELEC Resolution No. 9371
- On March 6, 2012, the Commission on Elections issued Resolution No. 9371 prescribing the “Rules and Regulations on Person Deprived of Liberty (PDL) Registration and Voting.”
- Key provisions:
- Defined “persons deprived of liberty” (PDLs) eligible to register and vote.
- Constituted a Committee on PDL Voting.
- Established guidelines for PDL registration and voting.
- Designated special polling places inside jails and constituted Special Boards of Election Inspectors with support staff.
- Under Rule 1, Section 2(a), qualified PDLs include persons who:
- Filing of petition and relief sought
- Atty. Victor Aguinaldo filed a Rule 65 petition (in relation to Rule 64) for certiorari and prohibition with injunctive relief, challenging Resolution No. 9371.
- Grounds raised:
- Lack of implementing rules and regulations.
- Absence of prior public consultations.
- Equal protection violation by favoring PDL voters over other voter classes.
- Operational and logistical deficiencies creating uncertainties and loopholes.
- Prayers:
- Restrain and prohibit the application of Resolution No. 9371 in future elections.
- Declare the assailed provisions unconstitutional or of no force and effect.
- Require COMELEC to revisit, amend, and revise the resolution before implementation.
- Procedural history
- February 3, 2016: Office of the Solicitor General filed a Comment defending the procedural validity and presumptive constitutionality of Resolution No. 9371.
- April 19, 2016: The Court partially granted a Temporary Restraining Order—enjoining application of specified provisions to the 2016 local elections, but allowing PDL voting in the national elections.
- May 3, 2016: COMELEC issued Resolution No. 10113 with general instructions for counting and canvassing PDL votes for local candidates.
- March 13, 2019: Commission on Human Rights intervened as amicus curiae, urging dismissal to protect PDL electoral participation.
- March 3, 2020; May 4, 2021: The Court required, then dispensed with, comments from enrolled PDL voters in light of the upcoming 2022 elections.
Issues:
- Whether the petition satisfies the four requisites for judicial review:
- Existence of an actual and appropriate case or controversy.
- Personal and substantial interest of the petitioner (locus standi).
- Exercise of judicial review pleaded at the earliest opportunity.
- The constitutional question is the lis mota of the case.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)