Case Digest (G.R. No. 257610) Core Legal Reasoning Model
Facts:
This case arose from two consolidated Petitions for Certiorari and Prohibition challenging the constitutionality of Section 8 of Republic Act No. 7941 (Party-List System Act) and Sections 5(d) and 10 of COMELEC Resolution No. 10717. Petitioners Glenn Quintos Albano and Catalina G. Leonen-Pizarro were nominees of sectoral party-lists for the 2022 national elections but were barred by the respondent Commission on Elections (COMELEC) from nomination because both had lost bids for elective office in the immediately preceding May 2019 elections. Albano was the second nominee of Talino at Galing ng Pinoy Party-List; he previously lost as city councilor of Taguig in 2019. Pizarro was the first nominee of Arts Business and Science Professionals (ABS) Party-List; she lost her bids for mayor of Sudipen, La Union in 2016 and 2019. Section 8 of RA 7941 disqualified candidates who had lost in the immediate prior election from being party-list nominees; this was replicated in relevant COMELE
Case Digest (G.R. No. 257610) Expanded Legal Reasoning Model
Facts:
- Background
- Glenn Quintos Albano (Albano), second nominee of Talino at Galing ng Pinoy Party-List (TGP) in the 2022 elections, a natural born Filipino, registered voter, a member in good standing of the Philippine Bar with 15 years’ experience.
- Albano previously ran and lost for city councilor in Taguig City in 2019 and served as TGP’s Chief Political Affairs Officer and Chief of Staff.
- Catalina G. Leonen-Pizarro (Pizarro) is president and first nominee of Arts Business and Science Professionals (ABS) Party-List, served 3 consecutive terms (2007-2016) as ABS representative in the House.
- Pizarro unsuccessfully ran for mayor of Sudipen, La Union in 2016 and 2019.
- Disqualification under R.A. No. 7941 and COMELEC Resolution No. 10717
- Section 8 of R.A. No. 7941 bars persons who have lost an elective office bid in the immediately preceding election from being nominated as party-list representatives.
- COMELEC Resolution No. 10717, sections 5(d) and 10, adopted same bar for the 2022 elections.
- Albano’s and Pizarro’s nominations were disallowed based on these provisions.
- Procedural History
- Albano and Pizarro filed separate petitions for certiorari and prohibition challenging constitutionality of Section 8 of R.A. No. 7941 and related COMELEC resolutions.
- Petitions consolidated under UDK No. 17230 and G.R. No. 257610.
Issues:
- Whether Congress may prescribe additional qualifications beyond the constitutional minimum for party-list representatives.
- Whether the limitation barring persons who lost in the immediately preceding elections from nomination as party-list representatives violates the equal protection clause of the 1987 Constitution.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)