Case Digest (G.R. No. 203766) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Atong Paglaum, Inc. et al. v. Commission on Elections (G.R. No. 203766 et al., April 2, 2013), fifty-four consolidated petitions for certiorari were filed by forty-five party-list groups challenging the COMELEC En Banc resolutions that disqualified them from the May 13, 2013 party-list elections. Under Republic Act No. 7941 and COMELEC Resolutions Nos. 9366 and 9513, some groups’ petitions for initial registration were denied, while others had their prior registration and accreditation cancelled after summary hearings. Petitioners included both sectoral organizations (e.g., Alliance for Rural and Agrarian Reconstruction, AANGE, ABANG LINGKOD) and political parties (e.g., AKO Bicol, ANAD), represented in earlier ballots or newly applying. Each COMELEC division first acted on registrations, then the En Banc automatically reviewed approvals, held summary evidentiary hearings on existing registrants’ compliance, and issued resolutions disallowing participation. All petitioners se Case Digest (G.R. No. 203766) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Consolidation of Petitions
- Fifty-four (54) petitions were filed by fifty-two (52) party-list groups challenging COMELEC resolutions disqualifying them from the May 13, 2013 party-list elections.
- The petitions included new applicants whose registration was denied and previously registered groups whose accreditation was cancelled.
- Legal and Procedural Background
- Republic Act No. 7941 (RA 7941) implemented the 1987 Constitution’s party-list provisions (Art. VI, Sec. 5).
- COMELEC Resolution No. 9366 (Feb. 21, 2012) set registration requirements; Resolution No. 9513 (Aug. 2, 2012) ordered automatic review of new registrations and summary hearings to verify continuing compliance.
- The Court previously laid down guidelines in Ang Bagong Bayani v. COMELEC (2001) and adjusted the seat-allocation formula in BANAT v. COMELEC (2009).
Issues:
- Did the COMELEC En Banc commit grave abuse of discretion by:
- Automatically reviewing Division rulings without motions for reconsideration?
- Conducting summary hearings and cancelling existing registrations?
- Should the COMELEC continue applying the Ang Bagong Bayani/BANAT criteria in the May 2013 party-list elections?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)