Title
Supreme Court
An Waray Party-List vs. Commission on Elections
Case
G.R. No. 268546
Decision Date
Aug 6, 2024
An Waray Party-List challenged the cancellation of its registration by COMELEC. The Supreme Court confirmed COMELEC's decision, affirming its jurisdiction over party-list matters, and ruled no violation of the right to speedy disposition occurred.

Case Summary (G.R. No. 268546)

Applicable Law

This analysis primarily relies on the provisions of the 1987 Philippine Constitution, particularly Article IX-C, which discusses the powers and functions of the Commission on Elections, along with Republic Act No. 7941, known as the Party-List System Act. Relevant sections include the authority of COMELEC to register or cancel the registration of national, regional, or sectoral parties, organizations, or coalitions.

Background and Facts

AN WARAY is a party-list organization that participated in the 2013 National and Local Elections (NLE), securing two seats in the House of Representatives after the elections. The controversy arose following the submission of a petition by Pornias and Acidre for the cancellation of AN WARAY's registration. They argued that Victoria Isabel Noel assumed her post as a member of the House without a proper proclamation, violating the rules under Section 6(5) of the Party-List System Act.

Ruling on Jurisdiction

The Court clarified that COMELEC has exclusive jurisdiction over the cancellation of party-list registrations as stipulated under the Constitution and relevant statutes. This authority allows COMELEC to determine whether an organization continues to meet registration criteria, irrespective of any implications on individual nominees seated in Congress. The pivotal determination here is that while the nominees serve as representatives, jurisdiction over the entity's registration lies with COMELEC.

Election Contests and Jurisdictional Boundaries

The exclusive jurisdiction of the House of Representatives Electoral Tribunal (HRET) covers contests related to the election returns and qualifications of its members. However, the case at hand pertains to the registration status of AN WARAY as an organization, not an individual’s qualification post-election. The ruling emphasizes that the cancellation of AN WARAY's registration does not qualify as an election contest but as a regulatory decision enforced by COMELEC.

COMELEC's Findings and Decision

COMELEC concluded that AN WARAY acted in violation of election laws by permitting a nominee who had not been validly proclaimed to assume office. The Court underscored that the actions leading to these violations constituted grounds for cancellation under the existing party-list regulations set forth in Republic Act No. 7941.

Right to Speedy Disposition of Cases

The petitioners contended that COMELEC's protracted timeline in processing the cancellation petition violated AN WARAY's right to a speedy resolution. The Court’s ruling highlighted that while delays were acknowledged, there was no proven prejudice resulting from the timeline, particularly as AN WARAY continued to participate in subsequent elections.

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