Title
Ang Bagong Bayani-OFW vs. Commission on Elections
Case
G.R. No. 147589
Decision Date
Jun 26, 2001
The Supreme Court ruled that the party-list system allows political parties but must prioritize marginalized sectors, remanding the case to Comelec for compliance review.
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Case Digest (G.R. No. 147589)

Facts:

    Background and Context

    • Two petitions were filed under Rule 65 challenging the validity of the Commission on Elections’ (COMELEC) Omnibus Resolution No. 3785, which approved the participation of 154 parties, organizations, and coalitions in the 2001 party‐list elections.
    • Petitioners include Ang Bagong Bayani-OFW Labor Party (represented by its Secretary-General, Mohammad Omar Fajardo) and Bayan Muna, both advocating that the party-list system is designed exclusively to benefit marginalized and underrepresented sectors rather than traditional or major political parties.

    Factual Development

    • With the onset of the 2001 elections, multiple sectoral and political parties filed petitions for registration and filed their Manifestations of Intent to participate within the prescribed deadlines.
    • COMELEC conducted extensive hearings reviewing more than a hundred such petitions, which led to the promulgation of a separate Omnibus Resolution on March 26, 2001, eventually accrediting 154 entities while denying others whose evidence was insufficient.
    • Some registered parties later filed motions for reconsideration and additional Manifestations even after the deadline, prompting disputes over whether to approve or disqualify the various groups.
    • Behind the scenes, there was a tension between the need for speedy action (due to the proximity of the elections) and the requirement to ensure that only parties truly representing marginalized sectors were allowed to participate.

    Proceedings Before the Court

    • Ang Bagong Bayani-OFW Labor Party filed a petition before the Supreme Court on April 16, 2001, challenging COMELEC Resolution No. 3785 for allowing traditional political parties and organizations not representing the truly underrepresented to join the party-list system.
    • Simultaneously, Bayan Muna filed a similar petition on April 17, 2001, seeking disqualification of certain respondents on similar grounds.
    • The Supreme Court consolidated the petitions, ordered the submission of comments and memoranda, and set an oral argument on May 17, 2001, while directing COMELEC to refrain from proclaiming any winner in the party-list race pending further resolution.

    Contentions of the Parties

    • Petitioners argued that allowing major political parties to participate in the party-list elections defeats the social justice purpose of the system. They maintained that the provision was meant exclusively for organizations representing marginalized and underrepresented sectors.
    • Respondents, including COMELEC and the Office of the Solicitor General, contended that both the Constitution and Republic Act 7941 permit the participation of registered national, regional, and sectoral parties regardless of whether they come from traditionally marginalized sectors.
    • The dispute centered on whether the party-list system should be an exclusive venue for the underrepresented or an open system that merely requires all participating entities to comply with statutory qualifications.

Issue:

    Appropriateness of the Certiorari

    • Whether the petitioners’ recourse under Rule 65 is proper given that other plain, speedy, and adequate remedies might be available in the ordinary course of law.
    • Whether, in light of the urgency of the elections, the petition is justified even if there exist alternative administrative remedies.

    Scope of Participation in the Party-List System

    • Whether political parties, including major ones, can validly participate in the party-list elections under the Constitution and RA 7941.
    • Whether the party-list system is intended exclusively for marginalized and underrepresented sectors or is open to include any registered party, organization, or coalition that meets the statutory requirements.

    Allegation of Grave Abuse of Discretion

    • Whether COMELEC committed grave abuse of discretion by promulgating Omnibus Resolution No. 3785 without fully appreciating and applying the policy intended to reserve the system for marginalized sectors.
    • Whether the inclusion of groups that do not exhibit genuine representation of the disadvantaged contravenes the social justice objective embedded in the Constitution and the enabling law.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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