Case Digest (G.R. No. 222731) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Bagumbayan-VNP Movement, Inc. and Richard J. Gordon (hereafter “petitioners”) versus the Commission on Elections (“COMELEC”), petitioners sought a writ of mandamus against COMELEC to compel activation of the Voter Verified Paper Audit Trail (“VVPAT”) feature of vote-counting machines for the May 9, 2016 elections. Petitioners are a non-stock, non-profit corporation operating a registered national political party, and Gordon is its chairman, a registered voter, taxpayer, Senate candidate and principal author of Republic Act No. 9369 (which amended RA 8436, the Automated Election System law). RA 8436 (1997) authorized COMELEC to automate elections; RA 9369 (2007) prescribed “minimum system capabilities,” including VVPAT under Sections 6(e), (f), and (n). Despite acquiring vote-counting machines capable of printing voter receipts, COMELEC, by a 7–0 en banc vote and through Resolution No. 10057 (February 11, 2016), declined to activate VVPAT, citing speculative risks of vote-buyi Case Digest (G.R. No. 222731) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Petition
- Petitioners Bagumbayan-VNP Movement, Inc. (non-stock, non-profit corporation operating a registered national political party) and Richard J. Gordon (registered voter, taxpayer, senatorial candidate, Chair of Bagumbayan-VNP, author of Republic Act No. 9369) filed a Petition for Mandamus.
- Respondent Commission on Elections (COMELEC) is vested by the Constitution (Art. IX-C, Sec. 1(1)) to enforce and administer all election laws.
- Statutory Framework
- Republic Act No. 8436 (1997) authorized automated election systems; amended by Republic Act No. 9369 (2007) to expand security and audit features.
- Section 6 of RA 8436, as renumbered, sets “Minimum System Capabilities,” including:
- (e) Provision for voter verified paper audit trail (VVPAT)
- (f) System auditability with supporting documentation
- (n) A system enabling voter verification of machine-registered choices
- Technological and Administrative Background
- COMELEC used Precinct Count Optical Scan (PCOS) machines in 2010, 2013; adopted Vote-Counting Machines (VCMs) for 2016, capable of VVPAT.
- Petitioners allege COMELEC refused to enable VVPAT, citing risks of vote-buying, extended voting time (13 seconds per receipt), and potential challenges by losing candidates.
- COMELEC En Banc (7-0) Resolution No. 10057 (Feb. 11, 2016) provided general instructions for voting, counting, transmission but omitted VVPAT mechanisms.
- Procedural History
- Petitioners filed a Special Civil Action for Mandamus (Rule 65, Sec. 3) directly with the Supreme Court, seeking enforcement of Section 6(e), (f), (n).
- The Court required COMELEC to comment within five days; COMELEC moved for extension and failed to comply. The Court denied the motion, citing urgency and the fundamental right to vote verification.
Issues:
- Whether COMELEC unlawfully neglected its ministerial duty under RA 8436, as amended, to implement the VVPAT feature (Sec. 6(e), (f), (n)).
- Whether a writ of mandamus is the appropriate remedy to compel COMELEC to enable VVPAT on the vote-counting machines for the 2016 elections.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)