Case Digest (G.R. No. 206987)
Facts:
The case involves the Alliance for Nationalism and Democracy (ANAD) as the petitioner and the Commission on Elections (COMELEC) as the respondent. The core issue arose from a resolution issued by the COMELEC En Banc on November 7, 2012, which canceled ANAD's Certificate of Registration and/or Accreditation on three pivotal grounds: (1) ANAD's classification as not belonging to the marginalized and underrepresented sectors as detailed in Section 5 of Republic Act (R.A.) 7941; (2) the lack of proof that ANAD's nominees, Arthur J. Tariman and Julius D. Labandria, were legitimately nominated by the organization, since the submitted Certificate of Nomination included only three names; and (3) ANAD’s failure to provide its Statement of Contributions and Expenditures for the 2007 National and Local Elections, as mandated by Section 14 of R.A. 7166. ANAD sought judicial relief by contesting the resolution, asking the Supreme Court to compel the COMELEC to canvass votes in th
Case Digest (G.R. No. 206987)
Facts:
Background of the Case
The case involves a Petition for Certiorari filed by the Alliance for Nationalism and Democracy (ANAD) against the Commission on Elections (COMELEC). ANAD sought to compel COMELEC to canvass the votes cast for it in the 2013 Party-List Elections after its Certificate of Registration and Accreditation was cancelled.
Grounds for Cancellation
On 7 November 2012, the COMELEC En Banc cancelled ANAD's Certificate of Registration and Accreditation on three grounds:
- Failure to Represent Marginalized Sectors: ANAD did not belong to or represent the marginalized and underrepresented sectors as required by Section 5 of R.A. No. 7941.
- Insufficient Nominees: ANAD submitted only three nominees instead of the required five, violating Section 4, Rule 3 of Resolution No. 9366.
- Non-Compliance with Financial Reporting: ANAD failed to submit its Statement of Contributions and Expenditures for the 2007 National and Local Elections, as mandated by Section 14 of R.A. No. 7166.
Procedural History
ANAD challenged the COMELEC's resolution before the Supreme Court. In Atong Paglaum, Inc. v. COMELEC, the Court remanded the case to COMELEC for re-evaluation. However, in its 11 May 2013 Resolution, COMELEC reaffirmed ANAD's disqualification, citing violations of election laws and regulations.
ANAD's Arguments
ANAD argued that:
- COMELEC gravely abused its discretion by not conducting a summary evidentiary hearing, violating its right to due process.
- COMELEC erred in finding that ANAD submitted only three nominees and failed to submit its Statement of Contributions and Expenditures for the 2007 Elections.
Issue:
- Whether COMELEC gravely abused its discretion by not conducting a summary evidentiary hearing before issuing the assailed resolution.
- Whether COMELEC erred in finding that ANAD submitted only three nominees and failed to comply with financial reporting requirements.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Court upheld COMELEC's resolution, emphasizing that ANAD's disqualification was based on valid grounds and that COMELEC did not act with grave abuse of discretion. Even if ANAD were qualified, its vote count (200,972 votes) was insufficient to secure a seat in the House of Representatives.