Case Digest (G.R. No. 276456)
Facts:
Partido Federal ng Pilipinas and its National President Leandro B. Verceles, Jr., and on his own behalf as a party member, petitioners, vs. Commission on Elections, Reynaldo S. Tamayo, Jr., Thompson C. Lantion and George S. Briones, respondents, G.R. No. 276456, February 25, 2025, the Supreme Court En Banc, Singh, J., writing for the Court.Petitioners Leandro B. Verceles, Jr. (Verceles) and Antonio C. Rodriguez, Jr. (Rodriguez) filed an Omnibus Petition with the Commission on Elections (COMELEC) on March 6, 2024, claiming to have been elected National President and Secretary-General, respectively, of the Partido Federal ng Pilipinas (PFP) at a purported National Directorate Meeting on December 14, 2023. They invoked COMELEC jurisdiction under Article IX‑C, Section 2(5) of the 1987 Constitution and relied on the PFP’s 2018 Constitution and By‑laws (Article XVII, Sec. 2) that, they said, provided for two‑year terms for national officers.
Respondents Reynaldo S. Tamayo, Jr., Thompson C. Lantion, and George S. Briones (Tamayo, et al.) countered that the PFP’s governing instrument is the 2022 Constitution and By‑Laws, submitted to COMELEC on April 11, 2022, which sets three‑year terms for national officers, such that their terms expired in 2024, not in September 2023. They also asserted that they timely filed an updated Sworn Information Update Statement (SIUS) (electronically on September 29, 2023, with a physical receipt stamped October 4, 2023), while petitioners’ SIUS of December 20, 2023 was untimely and, in respondents’ view, falsified.
The COMELEC En Banc directed an Answer/Comment (May 7, 2024), set the case for hearing (May 27, 2024; hearing on June 4, 2024), and, after memoranda, resolved that it had jurisdiction to decide the intra‑party dispute as incident to its registration powers. The COMELEC En Banc, in a Resolution dated September 6, 2024, dismissed the COMELEC Petition for lack of merit, finding (inter alia) that the 2022 Constitution and By‑Laws were the controlling documents, that Tamayo, et al. remained incumbent officers (their term expiring in 2024), that the December 14, 2023 elections were invalid for lack of authority, notice and quorum, and that Tamayo, et al.’s SIUS filed within the COMELEC deadline was valid while petitioners’ SIUS was late. The COMELEC denied reconsideration in its October 3, 2024 Resolution.
Petitioners then brought a Petition for Certiorari under Rule 64 seeking reversal of the COMELEC Resolutions; they chiefly argued tha...(Subscriber-Only)
Issues:
- Did the COMELEC gravely abuse its discretion in holding that the 2022 Constitution and By‑laws of the PFP, providing for a three‑year term for its National Officers, are the valid authoritative documents governing the party?
- Did the COMELEC gravely abuse its discretion in ruling that Tamayo, et al. validly occupy the positions of President, Secretary General and General Counsel of the PFP?
- Did the COMELEC gravely abuse its discretion in recognizing the SIUS filed by Tamayo, et al. on September 29, 2023, and refusing to acknowledge Verc...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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