Case Digest (G.R. No. 203766)
Facts:
Petitioners were fifty-four consolidated Rule 64 petitions filed by fifty-two party-list groups and organizations challenging various Commission on Elections (COMELEC) En Banc resolutions disqualifying or cancelling their registration to participate in the 13 May 2013 party-list elections; the COMELEC acted under Republic Act No. 7941 and COMELEC Resolutions Nos. 9366, 9513 and related issuances, and many petitioners had obtained Status Quo Ante Orders or mandatory injunctions from this Court. The COMELEC divisions and the En Banc had denied registration or cancelled accreditation for failures said to include lack of marginal/sectoral representation, defective track record, nominees' disqualifications, and other grounds; the Court consolidated the petitions and heard the matters on expedited procedures.
Issues:
- Did the COMELEC commit grave abuse of discretion amounting to lack or excess of jurisdiction in disqualifying petitioners from the 13 May 2013 party-list elections?
- Should the qualification criteria for participation in the party-list system set forth in Ang Bagong Bayani and BANAT continue to govern the COMELEC in the 13 May 2013 party-list elections?
Ruling:
The Court held that the COMELEC did not commit grave abuse of discretion in following prevailing jurisprudence in disqualifying petitioners, but the Court GRANTED the consolidated petitions and adopted new parameters for party-list qualification, superseding the criteria applied by the COMELEC. The Court REMANDED all fifty-four petitions to the COMELEC for determination of qualification under the new parameters; petitioners already enjoying mandatory injunctions were remanded for COMELEC determination whether they qualified to participate in the 13 May 2013 elections, while those with only Status Quo Ante Orders were remanded for registration determination but not to participate in that election.
Ratio:
Reading Article VI, Section 5 of the 1987 Constitution together with R.A. No. 7941, the Court concluded the party-list system contemplates three distinct categories—national, regional and sectoral parties or organizations—and does not make the system exclusively sectoral; national and regional parties need not be organized along sectoral lines or prove they represent the marginalized. Because Ang Bagong Bayani and subsequent COMELEC practice had narrowed the system improperly (and BANAT compounded that narrowness), the Court adopted new, constitutionally grounded parameters for who may register and who nominees must be, and remanded the cases so COMELEC could apply those parameters in fact-finding hearings.
Doctrine:
- The party-list system under the 1987 Constitution comprises three groups—national, regional, and sectoral parties or organizations, and national and regional parties need not be organized on sectoral lines.
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