GR 191771; (May, 2010) (Digest)
G.R. No. 191771 ; May 6, 2010
LIBERAL PARTY, represented by its President Manuel A. Roxas II and Secretary General Joseph Emilio A. Abaya, Petitioner, vs. COMMISSION ON ELECTIONS, NACIONALISTA PARTY, represented by its President Manuel B. Villar and NATIONALIST PEOPLE’S COALITION, allegedly represented by its Chairman Faustino S. Dy, Jr., Respondents.
FACTS
The Nacionalista Party (NP) and the Nationalist People’s Coalition (NPC) filed a petition on February 12, 2010, for registration as a coalition (NP-NPC) and for accreditation as the dominant minority party for the May 2010 elections. The Liberal Party (LP), which had also filed for accreditation as the dominant minority party, opposed the petition. The LP argued that the NP-NPC was not a duly registered coalition at the time of filing, that the COMELEC en banc lacked jurisdiction as the petition should have been filed first with a Division, that procedural rules on filing were violated, that the petition was filed beyond the deadline for party registration, and that the coalition was a new entity whose members’ credentials could not be counted.
On April 12, 2010, the COMELEC en banc issued the assailed Per Curiam Resolution granting the NP-NPC’s application for registration as a coalition but deferring the resolution on its accreditation as the dominant minority party. The COMELEC en banc ruled it had direct administrative authority to act on the registration, that no deadline existed for coalition registration, and that the coalition was validly formed. The LP filed a petition for certiorari and prohibition, challenging this resolution.
ISSUE
Whether the COMELEC en banc committed grave abuse of discretion in granting the petition for registration of the NP-NPC coalition.
RULING
The Supreme Court DISMISSED the petition, finding no grave abuse of discretion by the COMELEC en banc. The legal logic centered on the nature of the COMELEC’s powers and the specific act of registering a coalition. The Court distinguished between the COMELEC’s quasi-judicial and administrative powers, as established in Baytan v. COMELEC. The registration of a political coalition is an administrative function, not a quasi-judicial one. The Constitution vests administrative powers in the “Commission on Elections” as a body, without requiring initial action by a Division. Therefore, the COMELEC en banc acted within its authority by directly resolving the registration petition.
Furthermore, the Court upheld the COMELEC’s finding that no statutory deadline applied specifically to the registration of coalitions, as opposed to the creation of new political parties. The COMELEC’s discretionary relaxation of its procedural rules to address the petition on its merits was also deemed a valid exercise of its authority, not a capricious act. Since the COMELEC’s actions were grounded in law and jurisprudence, and the LP failed to demonstrate a clear, arbitrary, or whimsical exercise of power, the petition for certiorari could not prosper. The alleged errors were, at most, errors of judgment not correctible by certiorari.