Title
Supreme Court
Chong vs. Senate of the Philippines
Case
G.R. No. 217725
Decision Date
May 31, 2016
Petitioners challenged the constitutionality of AC and TEC under R.A. 9369, alleging encroachment on COMELEC's mandate. SC dismissed, ruling AC/TEC roles advisory, non-binding, and supportive of clean elections.

Case Summary (G.R. No. 217725)

Relevant Legislation

The applicable law in this case centers around Republic Act No. 8436, enacted on December 22, 1997, which authorized the adoption of an Automated Election System (AES) for future elections, and the amendments provided by Republic Act No. 9369, signed into law on January 23, 2007. Particularly contentious are Sections 8, 9, 10, and 11 of R.A. No. 8436, as amended by R.A. No. 9369, which established the AC and the TEC.

Background of the Case

This case stems from the legislative provisions for implementing an AES aimed at ensuring credible and efficient elections in the Philippines. The creation of the AC and the TEC resulted from concerns about election security and technological efficacy. The function of these bodies was to assist COMELEC but raised questions about the independence of the electoral commission and the extent of Congressional authority in influencing election administration.

Petitioners' Arguments

The petitioners, Glenn A. Chong and Ang Kapatiran Party, argued that the creation of the AC and TEC was unconstitutional as it undermined COMELEC's independence and authority as laid out in Section 2(1), Article IX-C of the 1987 Constitution. They claimed that the advisory roles imposed by these bodies could dictate operational aspects of election management, thereby infringing on the regulatory powers that are constitutionally mandated to COMELEC. They further contended that various recommendations made by the AC prior to the 2016 elections were invalid.

Respondents' Position

In response, the respondents asserted that the existence of the AC and TEC did not impede COMELEC's constitutional mandate to enforce election laws. They maintained that these bodies serve to enhance the effectiveness of the AES and provide oversight without compromising the commission's independence. The respondents argued that the provisions in question have a presumption of constitutionality, consistent with legislative intent and the need for technical advisory support.

Legal Issue at Hand

The legal issue centers on the constitutionality of the provisions concerning the AC and TEC established by R.A. No. 8436, as amended. Specifically, it pertains to whether these provisions infringe on COMELEC’s exclusive powers to administer and enforce election laws as protected by the Constitution.

Court's Ruling

The Court ruled against the petitioners, holding that the provisions did not violate the Constitution. It determined that the roles of the AC and TEC are advisory and do not usurp COMELEC's authority. The Court clarified that these entities are created to assist in objectively assessing the technology an

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