G.R. No. L-51223 - National Development Co. vs. Province of Nueva Ecija

On November 20, 2003, Aklat-Asosasyon Para Sa Kaunlaran Ng Lipunan At Adhikain Para Sa Tao, Inc. (“Aklat”) filed its petition for re-qualification as a party-list organization for the May 2004 elections.
Aklat had previously participated in the 2001 elections but was disqualified by the Comelec for failing to comply with the eight-point guidelines established in the Ang Bagong Bayani-OFW Labor Party v. Comelec case.
In anticipation of a new filing, Aklat reorganized itself claiming to have aligned its purposes, membership, and programs with the mandatory guidelines required for party-list participation.

On January 8, 2004, the Comelec issued a resolution dismissing Aklat’s petition for re-qualification.
The rationale was based on Aklat’s failure to clearly demonstrate representation of the marginalized and underrepresented sectors as mandated by Section 5 of Republic Act No. 7941 (R.A. 7941).
The Comelec further noted that the petition only included a vague declaration of re-organization without indicating which specific groups among the diverse sectors were being represented.

Aklat filed a Motion for Reconsideration on January 14, 2004, asserting that it had undergone a fundamental reorganization targeting indigenous cultural communities, farm and factory workers, fisherfolk, and the youth.
On February 13, 2004, the Comelec denied this motion on three grounds:

The petition was filed beyond the deadline set by Comelec Resolution No. 6320 for registration of party-list organizations.
Aklat was never a registered party-list organization, having initially failed to conform to the eight-point guidelines from the Bagong Bayani case.
The Comelec’s decision not to extend the registration deadline was within its discretion as the agency best positioned to manage the pre-election requirements.

Aklat argued that under Section 5 of R.A. 7941, petitions for registration should be allowed up to ninety (90) days before the elections, meaning that its filing on November 20, 2003, was timely.
It claimed that Resolution No. 6320, which mandated a filing deadline of September 30, 2003, was an unconstitutional amendment of R.A. 7941.
Aklat maintained that its reorganization and the submission of documents evidencing its compliance with the eight-point guidelines should have sufficed for qualification as a party-list representative organization.

The OSG asserted that the Comelec had not committed grave abuse of discretion.
It emphasized that Resolution No. 6320 was within the scope of the authority granted by R.A. 7941 and was necessary to set a firm deadline for the registration and verification process.
The OSG further contended that Aklat’s petition contained significant defects, such as:

Inadequate verification—there was no clear evidence that the signatory (Mr. Dominador Buhain) was properly authorized by Aklat to verify or file the petition.
Aklat was only registered with the Securities and Exchange Commission on October 20, 2003, falling short of the one-year existence requirement.
Lack of proper documentation proving that its membership predominantly consisted of individuals from the marginalized and underrepresented sectors.

The Comelec reiterated that the ninety (90) days deadline prescribed in R.A. 7941 served as a prohibitive period and that Resolution No. 6320 was a valid administrative measure.
It observed that the documents submitted by Aklat did not conclusively prove that its members belonged to the marginalized and underrepresented sectors as mandated by law.
The significant overlap between the incorporators of Aklat and those of A.K.L.A.T.—an organization previously de-registered—undermined Aklat’s claim of a genuine reorganization.

The Court noted that Aklat failed to fulfill the first guideline of the Bagong Bayani case, which requires clear evidence—through constitutional documents, history, and track record—of representing marginalized sectors.
The factual findings of the Comelec, an administrative body with relevant expertise, were binding since there was no evidence to contradict them in the petition.
Overall, the petition for requalification was found deficient both procedurally and substantively.

Whether the filing deadline set by Comelec Resolution No. 6320, which required party-list petitions to be filed by September 30, 2003, was valid in light of R.A. 7941’s provision allowing filing up to ninety (90) days before the elections.
Whether Aklat’s reorganization and submission of documentary evidence sufficiently demonstrated that it represents the marginalized and underrepresented sectors, as required by Section 5 of R.A. 7941 and the guidelines of the Bagong Bayani case.
Whether the Comelec abused its discretion in dismissing both the initial petition and the subsequent Motion for Reconsideration on the basis of procedural and substantive deficiencies.
Whether the similarities between Aklat and A.K.L.A.T. (in terms of incorporators and organizational purpose) negated the claim of a genuine reorganization aimed at representing marginalized groups.