Case Digest (G.R. No. 147066)
Facts:
Akbayan‑Youth et al. v. Commission on Elections, G.R. Nos. 147066 and 147179, March 26, 2001, Supreme Court En Banc, Buena, J., writing for the Court.Petitioners — various youth organizations and individual students (collectively AKBAYAN‑Youth, SCAP, UCSC, MASP, KOMPIL II‑Youth, Alyansa, KALIPI, Patricia O. Picar, Myla Gail Z. Tamondong, et al., and separately Michelle D. Betito) — sought to compel the Commission on Elections (COMELEC) to conduct a special or additional voter registration before the May 14, 2001 general elections so that persons who turned eighteen or otherwise became eligible after COMELEC’s December 27, 2000 deadline could be registered.
The sequence began with a Senate public hearing called by Senator Raul Roco on January 25, 2001, where youth groups requested a two‑day nationwide special registration; two COMELEC commissioners and a consultant attended and two commissioners later submitted Memorandum No. 2001‑027 recommending limited additional registration days with safeguards. COMELEC senior staff largely advised against special registration because Section 8 of Republic Act No. 8189 prohibits registration beginning 120 days before a regular election and because operational preparations could not be completed.
On February 8, 2001 COMELEC adopted Resolution No. 3584 denying the request to conduct two additional registration days (February 17–18, 2001). Aggrieved, petitioners filed: (a) a petition for certiorari and mandamus (G.R. No. 147066) seeking to annul the COMELEC resolution and/or declare Section 8 unconstitutional, and to compel registration; and (b) a mandamus petition by Michelle Betito (G.R. No. 147179) asking similarly. The cases were consolidated; the Court required comments and set oral argument for March 16, 2001. The Solicitor General filed a manifestation urging prompt additional registration, but the COMELEC detailed its logistical timetable (projects of precincts, BEI constitution, printing schedules, computerized voters’ list, etc.) asserting operational impossibility to fit a special registration before May 14.
The ...(Pro-only)
Issues:
- Did the COMELEC commit grave abuse of discretion in issuing Resolution No. 3584 (denying the request for a two‑day special registration)?
- May this Court compel the COMELEC by writ of mandamus to conduct a special registration of voters during the 120‑day prohibited period before the M...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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