G.R. No. 134015 - Domino vs. Commission on Elections

The case involves the Liberal Party, represented by its President Francis N. Pangilinan and Secretary General Jose Christopher Y. Belmonte (petitioner), and the Commission on Elections (COMELEC) along with the Nacionalista Party, represented by its President Manuel B. Villar and Secretary General Alan Peter Cayetano (respondents).
The dispute arose from COMELEC’s issuance of resolutions governing the accreditation of political parties for the May 13, 2019 national and local elections.

On March 25, 2019, COMELEC issued Resolution No. 10514 setting the guidelines for accreditation.

The resolution outlined the criteria for determining the dominant majority party, dominant minority party, 10 major national parties, and 2 major local parties based on factors such as past election performance, number of incumbent officials, organizational structure, ability to field a complete slate of candidates, and other analogous circumstances.
An additional criterion—number of women candidates fielded from municipal to senatorial levels—was included pursuant to legislative provisions.

Following the promulgation of Resolution No. 10514, on April 10, 2019, the Liberal Party filed its Petition for Accreditation as the Dominant Minority Party.

On May 8, 2019, COMELEC En Banc issued Resolution No. 10538, declaring Partido Demokratiko Pilipino - Lakas ng Bayan as the Dominant Majority Party, the Nacionalista Party as the Dominant Minority Party, and accrediting the Liberal Party as one of the eight major political parties.
COMELEC applied a weighted point system based on the criteria in Resolution No. 10514.

The Nacionalista Party obtained higher points in key categories, including the number of incumbent officials, organizational strength, capacity to field a complete slate of candidates, and the number of women candidates.

Prior to Resolution No. 10538, Commissioner Luie Tito F. Guia, with concurrence from Commissioner Ma. Rowena Amelia V. Guanzon, raised reservations via a memorandum.

Their concern focused on the determination of the dominant minority party, emphasizing that it should be “a party that belongs to those that stand in opposition to the majority” in line with Section 274 of the Omnibus Election Code.

On July 1, 2019, the Liberal Party filed a Petition for Certiorari under Rule 64 in relation to Rule 65 of the Rules of Court.
The petitioner alleged that:

COMELEC committed grave abuse of discretion by not adhering to the mandated definition of “dominant opposition party” in the Omnibus Election Code when accrediting the Nacionalista Party as the dominant minority party.
The included criteria in Resolution No. 10514 were erroneous, particularly since the accredited Nacionalista Party was part of the ruling coalition and not an opposition party.

Annulment of Resolution No. 10538.
The establishment of clear guidelines for recognizing and accrediting the dominant minority party in future elections.

In response, the COMELEC and the Nacionalista Party submitted their respective comments defending the accreditation process.
Both respondents contended that the case was rendered moot by the conclusion of the 2019 elections, noting that the privileges attached to accreditation could no longer be availed—and that the petitioner’s prayer was essentially a request for an advisory opinion.
Historical practice was also cited, highlighting that the accreditation criteria had been consistently applied in previous electoral cycles.

Whether the Petition for Certiorari has been rendered moot by the conclusion of the May 13, 2019 national and local elections.
Whether any relief regarding the accreditation resolution would produce a practical effect given that the elections had already been conducted.

Whether the petitioner’s prayer—requesting annulment of Resolution No. 10538 and the establishment of guidelines—is tantamount to seeking an advisory opinion, which the Court does not issue.

Whether the COMELEC committed grave abuse of discretion by applying its own criteria for accrediting the dominant minority party instead of adhering to the definition provided by the Omnibus Election Code.

Whether COMELEC exceeded its constitutional and statutory powers in formulating, relying on, and applying the criteria in Resolutions No. 10514 and No. 10538.