Title
Duty to Energize the Republic Through the Enlightenment of the Youth Party-List vs. Commission on Elections
Case
G.R. No. 261123
Decision Date
Aug 20, 2024
Duterte Youth Party-List challenged COMELEC's approval of nominee substitution in P3PWD Party-List after elections. The Court found COMELEC acted with grave abuse of discretion, making its approval void and preserving the integrity of the party-list system.

Case Digest (G.R. No. 261123)
Expanded Legal Reasoning Model

Facts:

  • Background
    • The consolidated petitions involve Duterte Youth Party-List represented by Ronald Gian Carlo and Ducielle Marie Cardema (petitioners) challenging the Commission on Elections (COMELEC) and Komunidad ng Pamilya, Pasyente at Persons with Disabilities (P3PWD) Party-List, represented by nominees including Ma. Rowena Amelia V. Guanzon (respondents).
    • COMELEC adopted Resolution No. 9366 in 2012 regulating withdrawal and substitution of party-list nominees, amended by Resolution No. 10690 in 2021 which imposed new deadlines.
  • Timeline of Events
    • P3PWD filed its registration petition in March 2021.
    • P3PWD submitted nominees in October 2021; later filed withdrawal with substitution of nominees in November 2021, approved by COMELEC on November 24, 2021.
    • COMELEC published final list including P3PWD in December 2021.
    • After the May 2022 elections, P3PWD won one seat, and nominees started resigning en masse in June 2022.
    • P3PWD filed substitution of nominees including Guanzon after elections; COMELEC approved substitution on June 15, 2022 subject to publication.
    • Petitioners opposed the substitution citing deadlines and possible conflict of interest as Guanzon was former COMELEC Commissioner.
    • COMELEC denied opposition and proclaimed P3PWD’s nominees; Guanzon took oath June 23, 2022.
    • Supreme Court issued Temporary Restraining Order (TRO) on June 29, 2022 enjoining COMELEC and House of Representatives (HOR) from allowing Guanzon and substitutes to assume office.
  • Key Contentions
    • Petitioners question legality of substitution post-election and beyond COMELEC's deadlines, alleging violation of voters' right to information and conflict of interest.
    • Respondents assert COMELEC’s approval valid and substitution in accordance with law.
  • Procedural Developments
    • Petitioners filed urgent petition for certiorari on June 21, 2022; COMELEC resolved opposition and enforced TRO.
    • Petition for indirect contempt filed against Guanzon for alleged violations of TRO.
    • Oral arguments held; parties submitted memoranda.

Issues:

  • Procedural Issues
    • Standing of petitioners to contest COMELEC resolutions.
    • Correct legal remedy for challenging COMELEC’s administrative decisions.
    • Whether COMELEC’s minute resolutions were final determinations.
    • Whether COMELEC acted in quasi-judicial or administrative capacity.
    • Jurisdiction over the matter: COMELEC vs. House of Representatives Electoral Tribunal (HRET).
    • Whether petition was premature before COMELEC resolved opposition.
  • Substantive Issues
    • Validity and effectivity of deadlines for withdrawal and substitution of party-list nominees.
      • Mandatory nature of Resolution No. 10690 deadlines even after elections.
      • Validity of COMELEC resolutions with less than required number of votes.
      • Whether all nominees can withdraw simultaneously and conditions thereto.
    • Qualifications of substitute nominees under Republic Act No. 7941.
      • COMELEC’s authority to determine compliance of substitutes.
      • Eligibility of Guanzon given prior COMELEC office.
    • Proper oath for assumption of office.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster—building context before diving into full texts.