Facts:

The consolidated cases of Atong Paglaum, Inc. v. Commission on Elections (COMELEC) and others involve 54 petitions for certiorari filed by 52 party-list groups and organizations contesting the resolutions of the COMELEC that disqualified them from participating in the May 13, 2013 party-list elections. These petitions were driven by various grounds, including the denial of their petitions for registration and the cancellation of their existing registrations and accreditations as party-list organizations. The COMELEC had registered approximately 280 groups intending to participate in the elections, but it subsequently disqualified several after reviews and hearings under the Party-List System Act (RA 7941) and COMELEC Resolution Nos. 9366 and 9513. The COMELEC cited various reasons for disqualification, including failure to represent marginalized sectors, lack of a track record, and non-compliance with necessary procedural requirements like the submission of lists of qualified no

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Facts:

Consolidated Petitions and the Party‐List System

• Dozens of party‐list groups and organizations filed consolidated petitions challenging the Commission on Elections’ (COMELEC) resolutions.
• The contested resolutions either denied registration or cancelled the accreditation of various party‐list groups seeking to participate in the May 13, 2013 elections.
• The petitions were brought by groups that had either been previously registered and accredited or were new applicants under Republic Act No. 7941 (RA 7941), the Party‐List System Act.

The Context of the Party‐List System

• The 1987 Constitution provides that up to 20 percent of the membership of the House of Representatives is to be elected through a party‐list system comprised of registered national, regional, and sectoral parties or organizations.
• RA 7941 was enacted to implement this constitutional provision and to promote proportional representation for those “marginalized and under‐represented” groups who cannot win in traditional district elections.
• Over time, jurisprudence—including the landmark cases Ang Bagong Bayani and BANAT—has set guidelines regarding:
• The requirement that party‐list groups must represent marginalized and under‐represented sectors.
• The nature and qualifications of nominees submitted by these groups.
• The participation parameters for national and regional political parties.

COMELEC’s Actions and the Disputes Raised

• The COMELEC, through a series of resolutions, reviewed the eligibility of various party‐list groups using the guidelines from previous decisions (e.g., Ang Bagong Bayani).
• Issues arose over whether applying a narrow definition of “marginalized and under‐represented” and strict nominee requirements was appropriate.
• Some groups were disqualified solely because one or some nominees did not “factually belong” to the sector they claimed to represent.
• In addition, the COMELEC En Banc conducted automatic reviews and summary evidentiary hearings without the filing of a motion for reconsideration—raising procedural due process concerns.

Issue:

Scope and Validity of the Qualification Criteria

• Whether the COMELEC correctly interpreted and applied the requirement that party‐list groups must represent “marginalized and under‐represented sectors” as mandated by the Constitution and RA 7941.
• Whether national and regional political parties (or their separate sectoral wings) should be subjected to the same narrowly defined standard as sectoral groups.

Disqualification Based on Nominee Qualifications

• Whether the disqualification of party‐list groups solely on the failure of one or more nominees to satisfy the “marginalized” or “under‐represented” criterion is proper.
• The extent to which a party’s substantive qualifications should be separated from the qualifications of its individual nominees.

Procedural and Administrative Concerns

• Whether the COMELEC En Banc had the proper authority to review decisions without a prior motion for reconsideration in an administrative context.
• Whether the suspension of COMELEC procedural rules (such as the requirement for motions for reconsideration) in order to expedite the review violated due process or exceeded its jurisdiction.

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Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

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