Case Summary (G.R. No. 192984)
Facts
On March 31, 2010, Layug, acting as a concerned citizen, filed a petition to disqualify the Buhay Party-List from participating in the upcoming elections, alleging it was an extension of the El Shaddai religious sect. He contended that the party-list was disqualified under Article VI of the 1987 Constitution and the Party-List System Act due to its religious affiliation and that Brother Mike, a businessman, did not belong to the marginalized sector as required for party-list nominees. In response, Buhay Party-List claimed to represent various marginalized sectors, asserting that it was neither a religious sect nor disqualified.
Procedural Background
The COMELEC Second Division denied Layug’s petition on June 15, 2010, citing lack of substantial evidence. Layug, who claimed he had not received the decision due to a mailing error, later found the resolution was deemed served as his incorrect address prohibited proper notification. Consequently, the COMELEC declared the decision final and sent Buhay Party-List’s election results, proclaiming its nominees as winners.
Motion for Reconsideration
Layug filed a motion for reconsideration on July 28, 2010, claiming due process violations due to inadequate service of the resolution. However, the motion was denied for being out of time, leading Layug to file the current petition, alleging grave abuse of discretion by COMELEC.
Issues
The primary issues raised include: (1) Whether the COMELEC Second Division violated procedural due process by not serving Layug’s counsel; and (2) Whether the COMELEC En Banc unlawfully neglected to resolve Layug's timely motion for reconsideration after the finality of the earlier resolution.
Jurisdiction
The court ruled it had jurisdiction over the petition despite respondents’ claims that the House of Representatives Electoral Tribunal (HRET) held exclusive jurisdiction regarding the qualifications of representatives already assumed into office. The court clarified that the legal qualifications of political parties fall within the jurisdiction of COMELEC, particularly citing the Party-List System Act, thereby placing Layug’s petition under the court’s review authority.
Due Process
The ruling concluded that Layug was not denied due process. The court emphasized that the responsibility for providing correct address information lies with Layug. The failure to receive the resolution stemmed from his erroneous address, and thus, the assumption of receipt after unsuccessful delivery attempts was deemed valid. Layug's deliberate choice to provide an inexistent address revealed an intention to obstruct the proceedings.
Finality of Resolution
The court maintained that the finality of decisions is a jurisdictional matter, asserting that it cannot be influenced by a party’s convenience. Layug's attempts to leverage his own procedural
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Background of the Case
- Petitioner Rolando D. Layug filed a Petition to Disqualify Buhay Party-List and its nominee Mariano Velarde from the 2010 Party-List Elections.
- Layug claimed Buhay Party-List was an extension of the El Shaddai religious sect, disqualifying it under constitutional and statutory provisions.
- He also argued that Velarde, as a billionaire and spiritual leader, does not belong to the marginalized sectors required for party-list nominees.
- Buhay Party-List and Velarde countered that the party represents multiple sectors and insisted nominees need not always come from marginalized sectors.
Procedural History
- Layug filed the petition pro se with an address at #70 Dr. Pilapil St., Pasig City.
- Respondents served an Answer which Layug did not receive due to an allegedly invalid address.
- COMELEC Second Division denied the petition on June 15, 2010, citing lack of substantial evidence.
- COMELEC Second Division found Layug a "phantom petitioner" for giving a nonexistent address, deeming he received the Resolution on June 23, 2010.
- No timely motion for reconsideration was linked to this Resolution.
- COMELEC En Banc proclaimed Buhay Party-List as winner in the 2010 elections on July 30, 2010.
- Layug filed a motion for reconsideration on July 28, 2010, which was denied as filed out of time.
Issues Presented
- Whether the COMELEC Second Division violated procedural due process by not issuing notice of promulgation to Layug's counsel.
- Whether the COMELEC En Banc unlawfully neglected its duty by not ruling on Layug's timely filed motion for reconsideration.