G.R. No. 190793 - Magdalo Para Sa Pagbabago vs. Commission on Elections

On 2 July 2009, Magdalo sa Pagbabago (MAGDALO) filed a petition with the COMELEC Second Division to register/accredit as a regional political party in the NCR for the 10 May 2010 elections. It was represented by Senator Trillanes IV and Francisco Acedillo.
The COMELEC ordered publication in three newspapers and set a hearing on 3 September 2009. MAGDALO complied, presented its witness, submitted documentary evidence and filed a Formal Offer of Evidence.

On 26 October 2009, the COMELEC Second Division denied MAGDALO’s petition, citing its founders’ participation in the July 27, 2003 Oakwood mutiny—use of battle gear, explosives and purported hostage-taking—as evidence of seeking goals by violence and unlawful means.
MAGDALO filed a Motion for Reconsideration, then a Manifestation of Intent to participate in the party-list system, later amended “ex abundantia cautela” and clarified by a Manifestation and Motion for Early Resolution.
On 4 January 2010, the COMELEC En Banc denied reconsideration. MAGDALO sought a TRO and injunctive relief from the Supreme Court, which was denied on 2 February 2010.

The COMELEC maintained its authority to assess whether an applicant advocates force, a matter not reviewable in certiorari except for grave abuse of discretion.
The Supreme Court found the case not moot—registration was for future elections and fell under mootness exceptions—and proceeded to resolve the merits.

Whether the petition was rendered moot and academic by the 10 May 2010 elections.

Whether the COMELEC improperly took judicial notice of the Oakwood incident without evidence on record.
Whether the COMELEC erred in finding MAGDALO seeks to achieve its goals through violence or unlawful means.
Whether the COMELEC’s finding amounted to prejudgment of the criminal case and violated the presumption of innocence.