Title
Lakas ng Bayan vs. Commission on Elections
Case
G.R. No. L-47883
Decision Date
Mar 25, 1978
LABAN challenged COMELEC's decision to allow Nacionalista Party (NP) to adopt Kilusan ng Bagong Lipunan (KBL) candidates while maintaining separate ballot listing, alleging unfair advantage. The Supreme Court ruled no grave abuse of discretion, upholding coalition practices under the Election Code.

Case Digest (G.R. No. L-47883)

Facts:

The petitioner, Lakas ng Bayan (LABAN), filed a petition for prohibition and certiorari against the Commission on Elections (COMELEC) and the Nacionalista Party (NP). LABAN sought to enjoin COMELEC from granting NP the rights and privileges of a separate political party in the April 7, 1978 elections for the Interim Batasang Pambansa. LABAN argued that listing NP in the official ballot gave undue advantage to the Kilusan ng Bagong Lipunan (KBL) candidates, who were also NP candidates. LABAN claimed that COMELEC favored NP by center-setting and giving it "star billing" in the ballot, allowing KBL candidates to be voted for in six ways compared to LABAN's two. LABAN also contended that NP had become an adjunct of KBL, losing its independence and violating Section 140 of the Election Code, which prohibits a candidate from being in the ticket of more than one party. LABAN further argued that separate recognition of KBL and NP would give them future accreditation rights, media advantages, and increased campaign spending and watchers.

Issues:

  • Whether COMELEC committed grave abuse of discretion by allowing NP to adopt all KBL candidates while maintaining a separate listing in the ballot.
  • Whether COMELEC violated Section 140 of the Election Code, which provides that a candidate may be in the ticket of only one political party, group, or aggrupation.
  • Whether the listing of NP in the ballot gave undue advantage to KBL candidates, violating the constitutional mandate of fairness and equality in elections.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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