Atong Paglaum, Inc. vs. Commission on Elections

Facts:

Atong Paglaum, Inc. v. Commission on Elections, G.R. Nos. 203766, 203818-19, 203922, 203936, 203958, 203960, 203976, 203981, 204002, 204094, 204100, 204122, 204125, 204126, 204139, 204141, 204153, 204158, 204174, 204216, 204220, 204236, 204238, 204239, 204240, 204263, 204318, 204321, 204323, 204341, 204356, 204358, 204359, 204364, 204367, 204370, 204374, 204379, 204394, 204402, 204408, 204410, 204421, 204425, 204426, 204428, 204435, 204455, 204484, 204485, 204486, 204490 (consolidated), April 02, 2013, Supreme Court En Banc, Carpio, J., writing for the Court.

Pursuant to Republic Act No. 7941 and COMELEC resolutions implementing the party‑list registration process, some 280 groups sought to register or to confirm their continuing qualification to participate in the 13 May 2013 party‑list elections. The Commission on Elections (COMELEC) (divisions and later the En Banc) reviewed petitions and manifestations of intent and, applying this Court's prior party‑list jurisprudence (notably Ang Bagong Bayani‑OFW Labor Party v. COMELEC and BANAT v. COMELEC), denied registration or cancelled accreditation of numerous groups for reasons including: failure to represent a marginalized or underrepresented sector, lack of track record, nominees not belonging to claimed sectors, untruthful statements, or being government‑assisted/adjuncts of government.

A group of 54 petitions (filed by 52 party‑list groups) challenged COMELEC En Banc resolutions cancelling/denying registration. The petitions were brought mainly as certiorari/prohibition under Rule 64 in relation to Rule 65 of the Rules of Court. The Court consolidated the petitions and issued Status Quo Ante Orders; 39 petitioners obtained mandatory injunctions directing inclusion in the ballot, while 13 obtained only SQAOs without mandatory injunctions. COMELEC had already begun printing ballots; the consolidated petitions therefore sought both injunctive relief and review of COMELEC’s disqualification decisions. Each COMELEC forum (division → En Banc) issued...(Pro-only)

Issues:

• Did the COMELEC commit grave abuse of discretion amounting to lack or excess of jurisdiction in disqualifying petitioners from participating in the 13 May 2013 party‑list elections (by denying new registration petitions or cancelling existing registration/accreditation)?
• Should the COMELEC continue to apply the criteria laid down in Ang Bagong Bayani and BANAT in determining qualification to participate in the 13 May 2013 party‑list elections, o...(Pro-only)

Ruling:

• (Pro-only)

Ratio:

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Doctrine:

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