Title
Cadangen vs. Commission on Elections
Case
G.R. No. 177179
Decision Date
Jun 5, 2009
Civil Servants' petition for party-list registration denied by COMELEC due to lack of nationwide presence and untruthful statements; SC upheld COMELEC's discretion.
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Case Digest (G.R. No. 177179)

Facts:

  1. Petition for Registration: On September 13, 2006, the Alliance of Civil Servants, Inc. (Civil Servants), represented by its then-president Atty. Sherwin R. Lopez, filed a petition for registration as a sectoral organization under Republic Act (R.A.) No. 7941 (Party-List System Act). The organization claimed to represent past and present government employees and sought to participate in the party-list system.
  2. COMELEC's Initial Order: On December 11, 2006, the COMELEC Second Division required Civil Servants to submit a memorandum proving its nationwide presence, track record, financial capability, platform of government, officers, membership, and compliance with the Party-List System Act and the guidelines set in Ang Bagong Bayani-OFW Labor Party v. Commission on Elections.
  3. Submission of Documents: Civil Servants complied by submitting documents, including letters to election officers, a revised list of members, a list of incorporators, a financial statement, a platform of government, and a list of officers.
  4. Manifestation of Intent: On February 8, 2007, Civil Servants filed a manifestation of intent to participate in the May 14, 2007 National and Local Elections.
  5. Denial of Registration: On February 13, 2007, the COMELEC Second Division denied Civil Servants' petition for registration, citing its failure to prove nationwide presence and its submission of untruthful statements.
  6. Motion for Reconsideration: Civil Servants filed a motion for reconsideration, arguing that the law does not require nationwide presence for registration. The COMELEC en banc denied the motion on March 26, 2007, reiterating that the organization failed to prove its nationwide existence and capacity to represent marginalized sectors.

Issue:

  1. Whether the COMELEC gravely abused its discretion in denying Civil Servants' petition for registration as a sectoral organization under the party-list system.
  2. Whether the requirement of nationwide presence is a valid ground for denying registration under R.A. No. 7941.

Ruling:

The Supreme Court dismissed the petition. It held that the COMELEC did not gravely abuse its discretion in denying Civil Servants' registration. The Court emphasized that the COMELEC has the authority to require relevant information and to deny registration based on untruthful statements or failure to represent marginalized sectors. The Court also noted that it is not a trier of facts and cannot reevaluate the evidence presented to the COMELEC.

Ratio:

  1. Grave Abuse of Discretion: The Court reiterated that grave abuse of discretion occurs when a tribunal acts arbitrarily or despotically, amounting to a refusal to perform a duty enjoined by law. In this case, the COMELEC acted within its jurisdiction and did not abuse its discretion.
  2. COMELEC's Authority: Under R.A. No. 7941, the COMELEC has the power to require relevant information and to deny registration based on specific grounds, including untruthful statements. The requirement of nationwide presence was deemed necessary to assess the organization's capacity to conduct a campaign and represent a marginalized sector.
  3. Role of the Supreme Court: The Court's role is limited to determining whether there was grave abuse of discretion, not to reevaluate factual findings. The COMELEC's findings of fact are binding on the Court.
  4. Opportunity to Reapply: The dismissal of the petition does not preclude Civil Servants from reapplying for registration, provided it complies with the legal requirements.


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