Case Digest (G.R. No. 15574)
Facts:
In Laban ng Demokratikong Pilipino v. Commission on Elections, the LDP, a registered political party, became embroiled in an internal leadership dispute between its Chairman, Senator Edgardo J. Angara, and its Secretary General, Representative Agapito A. Aquino, over who had authority to endorse and sign its Certificates of Nomination for the May 10, 2004 elections. On December 8, 2003 the LDP’s General Counsel filed a Manifestation with the COMELEC, asserting that only Senator Angara or his written designees could sign nominations and that Aquino was placed on “indefinite forced leave,” while Ambassador Enrique A. Zaldivar was named Acting Secretary General. Aquino filed a Comment to disregard the Manifestation as unfounded. The parties failed to agree on a joint manifestation, prompting the COMELEC to treat the matter as a verified Petition, to which Aquino filed an Answer. During oral arguments, an Aquino-signed Certificate of Nomination for Senator Panfilo Lacson was filed.Case Digest (G.R. No. 15574)
Facts:
- Parties and Initial Dispute
- Laban ng Demokratikong Pilipino (LDP) is a registered national political party.
- Senator Edgardo J. Angara is Party Chairman; Representative Agapito A. Aquino is Secretary General.
- December 2003 Manifests and Counterclaims
- On December 8, 2003, LDP General Counsel filed a Manifestation with COMELEC:
- Only Chairman Angara (or his written designee) may endorse Certificates of Candidacy (COCs).
- Aquino was placed on “indefinite forced leave”; Ambassador Enrique A. Zaldivar designated Acting Secretary General.
- Prayer that COMELEC recognize only COCs so endorsed and nullify others.
- On December 16, 2003, Respondent Aquino filed a Comment:
- Argued Chairman lacks authority to discipline or suspend the Secretary General.
- Asked COMELEC to disregard the Manifestation as baseless.
- On December 22, 2003, Angara converted the Manifestation into a verified Petition (E.M. 03-018), attaching a National Executive Council (NEC) Resolution:
- NEC ratified Chairman’s actions to preserve party unity, including coalition with KNP and suspension of Aquino.
- NEC reaffirmed confidence in Angara to represent LDP externally.
- COMELEC Proceedings and Resolution
- December 26, 2003: COMELEC issued an Order requiring a verified petition; Angara’s Petition was already filed.
- December 30, 2003: Aquino filed his Answer; parties submitted oral arguments the same day.
- January 6, 2004: COMELEC en banc issued a Resolution identifying the sole issue as which LDP officer is authorized to authenticate party nominations.
- COMELEC, invoking “legal equity,” recognized two factions:
- “Angara Wing”—candidates endorsed by Chairman Angara.
- “Aquino Wing”—candidates endorsed by Secretary General Aquino.
- Each wing entitled to its own election‐committee representatives and precinct returns (odd/even precinct split).
- Petition for Certiorari to the Supreme Court
- Senator Angara filed a petition for certiorari, alleging grave abuse of discretion.
- Respondent Aquino and COMELEC filed Comments; Office of the Solicitor General filed a Manifestation supporting Angara.
Issues:
- Core Issue
- Under the LDP Constitution and By-Laws, who—Party Chairman or Secretary General—has the power to endorse and sign Certificates of Candidacy for official party nominees?
- Jurisdictional and Discretion Issue
- Whether the COMELEC acted with grave abuse of discretion and exceeded its authority by splitting the LDP into two “wings” and allocating election privileges accordingly.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)