Case Summary (G.R. No. 206952)
Petitioner Profile
- Registered as a sectoral party-list on December 22, 2009; participated in the 2010 elections without winning a seat.
- Filed a Manifestation of Intent to participate in the May 2013 elections on May 31, 2012.
- Submitted documentary proof and photographs of purported sectoral activities to demonstrate continuing compliance with Republic Act No. 7941.
Respondent Role
- Issued Resolution No. 9513 (August 2, 2012) ordering summary hearings to verify continuing compliance of previously registered party-list groups.
- Held summary hearings on August 17, 31, and September 3, 2012; petitioner missed witness presentation.
- En Banc Resolution (November 7, 2012) cancelled petitioner’s registration for failure to prove a track record and for allegedly submitting digitally altered photographs.
- Enforced remand under Atong Paglaum (April 2, 2013) but, on May 10, 2013, affirmed cancellation sans new hearing, citing proximity to elections.
Chronology of Proceedings
- December 22, 2009 – Petitioner’s initial registration.
- May 31, 2012 – Manifestation of intent for 2013 elections.
- August 2, 2012 – COMELEC Resolution 9513 mandates evidentiary hearings.
- November 7, 2012 – Registration cancelled for lack of track record.
- April 2, 2013 – Supreme Court’s Atong Paglaum sets new screening parameters.
- May 10, 2013 – COMELEC reaffirms cancellation without further hearing.
- May 13, 2013 – Elections held; petitioner garners 260,215 votes.
- October 22, 2013 – Supreme Court decision on certiorari petition.
Constitutional and Statutory Framework
- 1987 Constitution, Article VI, Section 5: Establishes a party-list system for national, regional, and sectoral parties.
- Republic Act No. 7941 (Party-List System Act):
• Section 5 – Petition for registration must attach constitution, by-laws, platform, list of officers, coalition agreement, and other required information.
• Section 6 – Grounds for cancellation include untruthful statements in the petition. - COMELEC Resolutions:
• No. 9366 (February 1, 2012) – Detailed documents and grounds for opposition or cancellation, including falsified submissions.
• No. 9513 (August 2, 2012) – Procedures for summary evidentiary hearings.
Issue 1: Alleged Denial of Due Process
Petitioner contended that COMELEC’s May 10, 2013 Resolution cancelled its registration without a summary evidentiary hearing, violating its right to due process under the Constitution.
Court’s Ruling on Due Process
- Due process requires notice and a fair opportunity to be heard, not necessarily a formal trial-type hearing.
- Petitioner had notice via Resolution 9513, filed its Manifestation of Intent and supporting documents, and was scheduled for hearings on three dates.
- Petitioner also filed a motion for reconsideration, dispelling any claim of total deprivation of hearing.
- Atong Paglaum did not mandate new hearings de novo; rather, it remanded for reassessment based on already-submitted evidence, permitting—but not requiring—COMELEC to hold further summary hearings.
- Conclusion: No denial of due process occurred.
Issue 2: Alleged Grave Abuse of Discretion
Petitioner alleged that COMELEC abused its discretion by cancelling its registration for lack of track record and for submitting altered photographs.
Court’s Ruling on Grave Abuse and Track Record
- The Supreme Court modified the party-list screening framework in Atong Paglaum, eliminating the general “track record” requirement for sectoral groups: it is sufficient that their principal advocacy pertains to the sector represented.
- Track record remains relevant only for nominees who do not belong to the sector they represent.
- Petitioner’s submission of digitally altered photographs pertained solely to its track record—a now-immaterial factor for sectoral group qualification.
- Requiring a sectoral party to prove track record despite constitutional and statutory amendments would unjustly burden marginalized sectors and contravene the Court’s new parameters.
Misrepresentation as Ground for Cancellation
- Section 6(6) of RA 7941 authorizes cancellation when a petition declares untruthful statements.
- Like material misrepresentation in individual candidacies, it must concern facts affecting a group’s qualification.
- Here, falsified photos did not influence petitioner’s core qualifications under the revised framework; they can
Case Syllabus (G.R. No. 206952)
Facts
- ABANG LINGKOD is a sectoral organization representing peasant farmers and fisherfolk, registered under the party-list system on December 22, 2009.
- It ran in the May 2010 elections but did not obtain a seat.
- On May 31, 2012, it filed a Manifestation of Intent to participate in the May 2013 elections.
- COMELEC Resolution No. 9513 (August 2, 2012) required all previously registered party-list groups with Manifestations of Intent to undergo summary evidentiary hearings to prove continuing compliance with R.A. No. 7941 and Ang Bagong Bayani guidelines.
- COMELEC set ABANG LINGKOD’s hearings on August 17, 31 and September 3, 2012; the group filed documents on August 16, 2012.
- On November 7, 2012, the COMELEC En Banc cancelled ABANG LINGKOD’s registration, finding no track record of advocacy and questioning the nominees’ sectoral status.
- ABANG LINGKOD filed a certiorari petition (G.R. No. 204220), later consolidated with 51 other petitions; status quo ante orders were issued.
- On April 2, 2013, the Supreme Court’s Atong Paglaum decision redefined party-list parameters and remanded cases to COMELEC for reassessment under new rules.
- On May 10, 2013, COMELEC En Banc issued the assailed Resolution affirming cancellation without further hearing, citing proximity to elections and alleging digitally altered photographs as unlawful statements.
- ABANG LINGKOD sought reconsideration on May 12, 2013, withdrew it on May 15, 2013, and filed the instant certiorari petition (G.R. No. 206952).
Issues
- Whether ABANG LINGKOD was denied due process when COMELEC affirmed its registration