Case Digest (G.R. No. 111656)
Facts:
This case involves the Magkakasama sa Sakahan, Kaunlaran (MAGSASAKA) Party-list, represented by its Secretary-General Atty. General D. Du, as the petitioner, versus the Commission on Elections (COMELEC) and Soliman Villamin, Jr., as respondents. The controversy arose in connection with the May 9, 2022 National and Local Elections, where two Manifestations of Intent to Participate (MIP) were filed under MAGSASAKA's name; one by Atty. Du as Secretary-General and another by Villamin, who claimed to be the National Chairperson. Atty. Du contended that Villamin was expelled from the party due to his involvement in anomalous activities related to DV Boer, Inc., a family corporation accused of engaging in ponzi or pyramiding schemes. Consequently, Villamin and several others were suspended and ultimately removed from leadership positions during a General Assembly held on December 21, 2019. Villamin argued that he was not properly notified of these meetings and challenged the valid
Case Digest (G.R. No. 111656)
Facts:
- Parties and Background
- Magkakasama sa Sakahan, Kaunlaran (MAGSASAKA) Party-list, represented by Secretary General Atty. General D. Du (Atty. Du), is a duly accredited regional party registered by COMELEC on January 17, 2019.
- For the May 9, 2022 National and Local Elections, two separate Manifestations of Intent to Participate (MIP) were filed under the name MAGSASAKA: one by Atty. Du as Secretary General and another by Soliman Villamin, Jr. (Villamin), claiming to be National Chairperson.
- Intra-Party Leadership Dispute
- Atty. Du and others filed petitions to deny due course Villamin's MIP, asserting Villamin was no longer National Chairperson, having been expelled due to involvement in fraudulent activities akin to Ponzi or pyramid schemes via DV Boer, Inc., Villamin’s family corporation.
- The Council of Leaders of MAGSASAKA received complaints and conducted investigations starting June 2019, which led to Villamin's suspension and eventually removal and expulsion through General Assembly meetings held in December 2019 and June 2021.
- Villamin contested the validity of his removal, asserting procedural infirmities, lack of notice, and questioned quorum and voting procedures.
- COMELEC Proceedings
- The COMELEC First Division issued a resolution on November 25, 2021, finding Villamin's removal violated the party’s rules on due process, lacked valid notice, and proper procedures; thus, Villamin remained the lawful National Chairperson when filing the MIP.
- COMELEC En Banc affirmed this position on September 9, 2022, clarifying its jurisdiction over intra-party leadership disputes and due process issues incidental to party registration.
- MAGSASAKA secured a seat in the May 9, 2022 elections, but COMELEC did not issue a Certificate of Proclamation. Subsequently, COMELEC issued a certificate proclaiming Roberto Gerard L. Nazal, Jr. (Nazal), Villamin's nominee, as the party's representative.
- Petition for Certiorari before the Supreme Court
- MAGSASAKA filed a Petition for Certiorari alleging grave abuse of discretion by COMELEC, arguing:
- Villamin should have been declared in default due to belated filings.
- MAGSASAKA was denied the right to cross-examine witnesses.
- COMELEC unlawfully interfered in intra-party disputes.
- Villamin’s MIP should have been denied due to misrepresentation.
- COMELEC improperly ruled on due process violations.
- Villamin opposed, reiterating COMELEC findings.
- COMELEC, via the Office of the Solicitor General, defended its actions emphasizing discretion, limited jurisdiction, and absence of grave abuse.
Issues:
- Did the COMELEC commit grave abuse of discretion in admitting Villamin's belated Answer and Joint Judicial Affidavit and in not declaring him in default?
- Was Villamin validly removed as National Chairperson of MAGSASAKA according to the party’s Saligang Batas (Constitution and By-laws)?
- Did the COMELEC exceed its jurisdiction in ruling on intra-party leadership disputes and due process compliance?
- Should Villamin's MIP be denied due course based on his alleged lack of authority and misrepresentation?
- Was the issuance of Certificate of Proclamation to Nazal valid given the ongoing disputes?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)