Ang Bagong Bayani-OFW Labor Party vs Ang Bagong Bayani- OFW Labor Party GO!

GO Philippines, et al
[G.R. No. 147589. G.R. No. 147613. June 26, 2001]
Facts:
On the registration period, the COMELEC approved the accreditation of 154 parties and
organizations but denied those of several others in its assailed Omnibus Resolution No. 3785.
Moreover, Akbayan Citizens Action Party filed before the COMELEC a petition to delete from
the Certified List of Political Parties/ Sectoral Parties/ Organizations/ Coalitions and that said
certified list be accordingly amended. Bayan Muna and Bayan Muna- Youth also filed a petition
for cancellation of Registration and Nomination against some herein respondents.
Ang Bagong Bayani- OFW Labor Party filed a petition assailing the COMELEC Omnibus
Resolution No. 3785. Also, Bayan Muna filed a petition challenging the said resolution.
Issues:
1. Whether or not the COMELEC committed grave abuse of discretion in promulgating Omnibus
Resolution No. 3785
2. Whether or not political parties may participate in the party-list elections
3. Whether or not party-list system is exclusive to marginalized sectors.
Ruling:
1. From its assailed Omnibus Resolution, COMELEC failed to appreciate fully the clear policy of
the law and the Constitution in connection with the due process clause. Basic rudiments of due
process require that the organizations or parties should first be given an opportunity to show that
they qualify under the guidelines promulgated before they can be deprived of their right to
participate in and be elected under the party-list system.
2. Yes, political parties may participate in the party-list elections.
Section 5, Article VI of the Constitution provides that members of the House of Representatives
may "be elected through a party-list system of registered national, regional, and sectoral parties
or organizations."Furthermore, under Sections 7 and 8, Article IX (C) of the Constitution,
political parties may be registered under the party-list system.

For its part, Section 2of RA 7941 also provides for "a party-list system of registered national,
regional and sectoral parties or organizations or coalitions thereof, x x x." Section 3 expressly
states that a "party" is "either a political party or a sectoral party or a coalition of parties.
3.

No, the state policy focused mainly on proportional representation by means of Filipino-style
party-list system.
Proportional representation here does not refer to the number of people in a particular district,
because the party-list election is national in scope. Neither does it allude to numerical strength in
a distressed or oppressed group. Rather, it refers to the representation of the marginalized and
underrepresented as exemplified by the enumeration in Section 5 of the law; namely, labor,
peasant, fisherfolk, urban poor, indigenous cultural communities, elderly, handicapped, women,
youth, veterans, overseas workers, and professionals.
While the enumeration of marginalized and underrepresented sectors is not exclusive, it
demonstrates the clear intent of the law that not all sectors can be represented under the party-list
system. It is a fundamental principle of statutory construction that words employed in a statute
are interpreted in connection with, and their meaning is ascertained by reference to, the words
and the phrases with which they are associated or related.

Atienza vs COMELEC
[G.R. No. 188920. February 16, 2006]
Facts:
Drilon, the former president of the Liberal Party (LP) announced that his party withdrew support
for the administration of former Pres. Gloria Macapagal- Arroyo. However, Atienza, LP
Chairman, alleged that Drilon made the announcement without consulting first the party.
Atienza hosted a party conference which resulted to the election of new officers, with Atienza as
LP president. Drilon immediately filed a petition with the COMELEC to nullify the said election
claiming that it was illegal considering that the partys electing bodies, NECO and NAPOLCO,
were not properly convened. Moreover, Drilon claimed that under the LP Constitution, there is a

three-year term. Meaning, his term has not yet ended. However, Atienza contested that the
election of new officers could be likened to people power removing Drilon as president by direct
action. Also, Atienza alleged that the amendment to the LP Constituion providing the three-term
had not been properly ratified.
The COMELEC held that the election of Atienza and others was invalid since the electing
assembly did not convene in accordance with the LP Constitution. Moreover, the COMELEC
ruled that since the said Constitution was not ratified, Drilon was only sitting in a hold-over
capacity since his term has been ended already.
Subsequently, the LP held a NECO meeting to elect new party leaders before respondent Drilons
term expired which resulted to the election of Roxas as the new LP president. Atienza et al.
sought to enjoin Roxas from assuming the presidency of the LP questioning the validity of the
quorum. The COMELEC issued resolution denying petitioners Atienza et al.s petition. As for
the validity of petitioners Atienza, et al.s expulsion as LP members, the COMELEC observed
that this was a membership issue that related to disciplinary action within the political party. The
COMELEC treated it as an internal party matter that was beyond its jurisdiction to resolve.
Issue:
Whether or not the COMELEC has jurisdiction over intra-party dispute
Ruling:
The COMELECs jurisdiction over intra-party disputes is limited. It does not have blanket
authority to resolve any and all controversies involving political parties. Political parties are
generally free to conduct their activities without interference from the state. The COMELEC
may intervene in disputes internal to a party only when necessary to the discharge of its
constitutional functions.
The Court ruled in Kalaw v. Commission on Elections that the COMELECs powers and
functions under Section 2, Article IX-C of the Constitution, include the ascertainment of the
identity of the political party and its legitimate officers responsible for its acts. Moreover, the

COMELECs power to register political parties necessarily involved the determination of the
persons who must act on its behalf. Thus, the COMELEC may resolve an intra-party leadership
dispute, in a proper case brought before it, as an incident of its power to register political parties.
The COMELEC did not err when it upheld Roxas election but refused to rule on the validity of
Atienzas expulsion.
Coquilla vs. Comelec
G.R. No. 151914, 31 July 2002 [Citizenship; Reacquisition]
FACTS:
Coquilla was born on 1938 of Filipino parents in Oras, Eastern Samar. He grew up
and resided there until 1965, when he was subsequently naturalized as a U.S.
citizen after joining the US Navy. In 1998, he came to the Philippines and took out a
residence certificate, although he continued making several trips to the United
States.
Coquilla eventually applied for repatriation under R.A. No. 8171 which was
approved. On November 10, 2000, he took his oath as a citizen of the Philippines.
On November 21, 2000, he applied for registration as a voter of Butunga, Oras,
Eastern Samar which was approved in 2001. On February 27, 2001, he filed his
certificate of candidacy stating that he had been a resident of Oras, Eastern Samar
for 2 years.
Incumbent mayor Alvarez, who was running for re-election sought to cancel
Coquillas certificate of candidacy on the ground that his statement as to the two
year residency in Oras was a material misrepresentation as he only resided therein
for 6 months after his oath as a citizen.
Before the COMELEC could render a decision, elections commenced and Coquilla
was proclaimed the winner. On July 19, 2001, COMELEC granted Alvarez petition
and ordered the cancellation of petitioners certificate of candidacy.
ISSUE:
Whether or not Coquilla had been a resident of Oras, Eastern Samar at least on year
before the elections held on May 14, 2001 as what he represented in his COC.
RULING:
No. The statement in petitioners certificate of candidacy that he had been a
resident of Oras, Eastern Samar for two years at the time he filed such certificate

is not true. The question is whether the COMELEC was justified in ordering the
cancellation of his certificate of candidacy for this reason. Petitioner made a false
representation of a material fact in his certificate of candidacy, thus rendering such
certificate liable to cancellation. In the case at bar, what is involved is a false
statement concerning a candidates qualification for an office for which he filed the
certificate of candidacy. This is a misrepresentation of a material fact justifying the
cancellation of petitioners certificate of candidacy. The cancellation of petitioners
certificate of candidacy in this case is thus fully justified.

SUNGA vs COMELEC Case Digest

SUNGA vs. COMELEC
288 SCRA 76
Facts:
Petitioner was one of the candidates for the position of Mayor in the Municipality of
Iguig, Cagayan in the May 1995 Elections. Private respondent Trinidad was then the
incumbent Mayor, was a candidate for re-election in the same municipality.
Sunga filed a complaint accusing Trinidad of violation of the Omnibus Election Code for
using threats, intimidation, terrorism or other forms of coercion. Hearings were held
wherein Sunga adduced evidence while Trinidad opted not to submit any evidence.
The election results showed that Trinidad garnered the highest number of votes while
Sunga trailed second.
The complaint filed by Sunga was denied by COMELEC ruling that the petitions filed
shall be deemed to be the amended petition filed on May 11,1995 which was clearly
filed after the election mandates the dismissal of the disqualification case.
Issue: Whether or not COMELEC can hear and decide disqualification cases against
winning candidates even after the election.
Held: The Supreme Court ruled that COMELEC is left with no discretion but to proceed
with the disqualification case even after the election. The fact that Trinidad was already
proclaimed and has assumed the position of mayor did not divest the COMELEC of
authority and jurisdiction to continue the hearing and eventually decide the
disqualification case. The fact that the candidate who obtained the highest number of
votes is later disqualified for the office to which he was elected does not entitle the
candidate who obtained the second highest number of votes to be declared the winner
of the elective office. Hence, Sunga cannot claim the right to take the oath for the
mayoral office because the Local Government Code clearly provides that in case of
disqualification of the one proclaimed for the said office, the vice-mayor shall assume
office.