Case Digest (G.R. No. 221318)
Facts:
Kabataan Party-List, represented by Representative James Mark Terry L. Ridon et al., G.R. No. 221318, December 16, 2015, the Supreme Court En Banc, Perlas-Bernabe, J., writing for the Court. Petitioners are youth and student organizations and officers (collectively, Kabataan Party-List and allied student groups) who challenged the constitutionality of Republic Act No. 10367 (the Biometrics Law) and related COMELEC implementing rules: COMELEC Resolution Nos. 9721, 9863, and 10013.
On February 15, 2013 Congress enacted RA 10367, which mandates mandatory biometrics registration for new voters and requires registered voters whose biometrics have not been captured to submit for validation, with noncompliance carrying the penalty of deactivation (Sections 3, 7, 10). The COMELEC promulgated Resolution No. 9721 (June 26, 2013) as implementing rules, commenced biometrics registration July 1, 2013, and later issued Resolution Nos. 9863 (April 1, 2014) and 10013 (November 3, 2015) to refine deactivation and hearing procedures; the COMELEC also ran a NoBio‑NoBoto public information campaign from May 2014 to October 31, 2015 and established satellite registration sites.
On November 25, 2015 petitioners filed a petition for certiorari and prohibition with application for a temporary restraining order (TRO) and/or writ of preliminary mandatory injunction, assailing RA 10367 and the COMELEC resolutions on several grounds: that biometrics validation is an unconstitutional substantive qualification (violating Art. V, Sec. 1, 1987 Constitution), that deactivation is not a constitutionally recognized disqualification, that the measure fails strict scrutiny, that due process is denied by summary deactivation procedures and short notice, and that fixing the validation deadline contravened Section 8 of RA 8189 (Voter’s Registration Act of 1996). Petitioners also invoked a separate pending petition (G.R. No. 220918).
The Court required COMELEC’s comment and on December 1, 2015 issued a TRO enjoining COMELEC from deactivating registration records pending resolution. COMELEC urged lifting the TRO by letter (Dec. 7, 2015) citing operational disruptions to finalizing ...(Subscriber-Only)
Issues:
- Are the procedural objections (failure to implead Congress, the Office of the President, and the Election Registration Board; alleged lack of standing; and the mode of review chosen) fatal to petitioners’ case?
- Does RA 10367 and the COMELEC Resolutions impose an unconstitutional substantive qualification on the right of suffrage in violation of Article V, Section 1 of the 1987 Constitution?
- If treated as a regulation of suffrage, does the biometrics validation requirement survive strict scrutiny as a justified and narrowly tailored measure?
- Do the deactivation procedures under RA 10367 and the COMELEC Resolutions violate procedural due process because of short notice, summary hearings, or inadequate opportunity to be heard?
- Does Resolution No. 9863’s fixation of the validation deadline (and acts that follow...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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