G.R. No. 221318 - Kabataan Party-List vs. Commission on Elections

Case Summary (G.R. No. 221318)

Key Dates

• February 15, 2013 – RA 10367 enacted.
• June 26, 2013 – COMELEC Resolution No. 9721 issued (implementing rules).
• April 1, 2014 – Resolution No. 9863 amended deactivation deadlines.
• November 3, 2015 – Resolution No. 10013 prescribed final deactivation procedures.
• December 1, 2015 – Temporary restraining order (TRO) granted.
• December 16, 2015 – Supreme Court decision dismissing the petition and dissolving the TRO.

Applicable Law

• 1987 Constitution, Art. V, Sec. 1 – qualifications and procedural limits on suffrage.
• RA 8189 (Voter’s Registration Act of 1996) – general registration, deactivation and reactivation rules.
• RA 10367 – mandatory biometric validation of voters.
• Omnibus Election Code (BP Blg. 881) – permissible disqualifications and registration requirements.

Issue Presented

Whether RA 10367 and COMELEC Resolutions Nos. 9721, 9863, and 10013 impose an unconstitutional “substantive” qualification on the right of suffrage by deactivating voters who fail to undergo biometric validation.

Procedural Objections and Public Importance

COMELEC argued that petitioners lacked standing, failed to implead indispensable parties, and misused certiorari. The Court, invoking the transcendental public importance of free and fair elections, waived these technical objections and resolved the petition on its merits.

Nature of Biometric Validation

The Court held that biometric validation under RA 10367 is a procedural extension of registration—not a substantive voting qualification proscribed by the Constitution. Registration and its updates are permissible regulatory measures under the State’s police power to ensure honest, orderly elections.

Constitutional Framework for Suffrage

Article V, Section 1 of the 1987 Constitution allows regulations of suffrage through procedural requirements but bars literacy, property, or “other substantive” qualifications unrelated to a voter’s ability to make an informed choice. The Court traced the historical elimination of property and literacy requirements, distinguishing them from procedural registration mandates.

Registration as Procedural Requirement

Citing prior jurisprudence, the Court reaffirmed that registration serves only to determine voter eligibility and is distinct from constitutional qualifications. RA 10367’s biometric requirement merely augments the validation process; its noncompliance results in deactivation but does not bar reactivation for those who later comply.

Strict Scrutiny Analysis

Applying strict scrutiny to the suffrage regulation, the Court found:
• Compelling interest: Establishing a clean, updated voters list to prevent fraud (e.g., multiple and ghost registrants).
• Narrow tailoring: Validation involves a single appearance with identity documents and the capture of photo, signature, and fingerprints.
• Least restrictive means: Continuous registration over 18 months, satellite registration sites, and an extensive information campaign (NoBio-NoBoto) demonstrated reasonable accommodation.

Due Process Compliance

COMELEC provided public notice by publication of RA 10367, posting of deactivation lists, individual notices, and summary Election Registration Board (ERB) hearings with opportunities for objection. The extended implementation period (July 2013 to October 2015) and heavy public information campaign satisfied proc