Case Digest (G.R. No. 221318) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Kabataan Party-List et al. v. Commission on Elections, G.R. No. 221318, decided December 16, 2015, petitioners Kabataan Party-List, represented by Rep. James Mark Terry L. Ridon and Marjohara S. Tucay, together with Sarah Jane I. Elago (President, National Union of Students of the Philippines), Vencer Mari E. Crisostomo and Einstein Z. Recedes (Chairperson and Deputy Secretary-General of Anakbayan), Marc Lino J. Abila (National President, College Editors Guild of the Philippines), Charisse Bernadine I. Baaez (Chairperson, League of Filipino Students), Arlene Clarisse Y. Julve (member, AGHAM), and Sining Maria Rosa L. Marfori challenged the constitutionality of Republic Act No. 10367 (“Biometrics Law”), enacted February 15, 2013, which mandated a mandatory biometric registration system for new voters and required validation of un-captured biometrics of existing registrants under threat of “deactivation.” They assailed also COMELEC Resolution No. 9721 (June 26, 2013 IRR), Resol Case Digest (G.R. No. 221318) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Enactment and Scope of Republic Act No. 10367
- On February 15, 2013, President Aquino signed RA 10367 (“Biometrics Law”), mandating a mandatory biometric registration system for new voters and validation for registered voters whose biometrics had not been captured.
- RA 10367 took effect 15 days after publication (February 22 – March 9, 2013), directing COMELEC to deactivate voters who fail to validate by the last day of filing for the May 2016 elections, with reactivation procedures under Section 28 of RA 8189.
- COMELEC Implementing Resolutions
- Resolution No. 9721 (June 26, 2013) set rules on validation, deactivation, and reactivation of voter registration records (VRRs); required posting and individual notices; and launched information campaigns.
- On July 1, 2013, COMELEC commenced biometrics registration, establishing satellite offices in barangays and malls.
- Subsequent Amendments and Campaigns
- Resolution No. 9863 (April 1, 2014) amended deadlines, fixing an October 31, 2015 cutoff for validation and deactivation hearings on November 16, 2015; COMELEC ran the “NoBio–NoBoto” campaign concurrently.
- Resolution No. 10013 (November 3, 2015) detailed deactivation procedures post–October 31 deadline, including bulletin postings, individual notices, objection periods (until November 9), and summary Election Registration Board (ERB) hearings.
- Petition for Certiorari and TRO
- On November 25, 2015, Kabataan Party-List and allied youth organizations filed a petition challenging the constitutionality of RA 10367 and COMELEC Resolutions Nos. 9721, 9863, 10013, arguing:
- Biometrics validation imposes an additional substantive qualification and deactivates voters outside constitutional disqualifications.
- Violation of the right to suffrage under strict scrutiny and denial of due process.
- Premature termination of registration period contrary to Section 8 of RA 8189.
- The Supreme Court issued a TRO (December 1, 2015) halting deactivations; COMELEC appealed and filed comments. Case was submitted for decision.
Issues:
- Are RA 10367 and COMELEC Resolutions Nos. 9721, 9863, and 10013 unconstitutional for:
- Imposing an additional, impermissible substantive qualification on suffrage through mandatory biometrics validation and deactivation?
- Violating the strict prohibition against literacy, property, or other substantive requirements in Article V, Section 1 of the 1987 Constitution?
- Breaching procedural due process rights by summary deactivation proceedings, inadequate notice, and short deadlines?
- Contravening the continuing registration system under Section 8 of RA 8189 by fixing an October 31, 2015 cutoff?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)