G.R. No. 221318 , December 16, 2015
KABATAAN PARTY-LIST, ET AL., PETITIONERS, VS. COMMISSION ON ELECTIONS, RESPONDENT.

FACTS

Petitioners, various youth and student organizations, assailed the constitutionality of Republic Act No. 10367 , the Mandatory Biometrics Voter Registration Act, and related COMELEC resolutions. The law required all registered voters to have their biometrics (photograph, fingerprints, and signature) captured by the COMELEC. It mandated that voters who failed to submit for biometrics validation by the deadline for the May 2016 elections—initially set for the last day of registration and later specified as October 31, 2015—would have their registration records deactivated and would be disenfranchised. The COMELEC implemented the law through resolutions, launching a “No Bio, No Boto” campaign and setting procedures for deactivation after notice and hearing by the Election Registration Board.
Petitioners argued the law and its implementing rules constituted an unconstitutional additional substantive requirement for the exercise of suffrage, impaired the right to vote, and violated due process. They contended that deactivation for non-compliance was a disenfranchisement not authorized by the Constitution or the Omnibus Election Code, which enumerates specific grounds for deactivation. They also claimed the public information campaign was insufficient, potentially disenfranchising millions, including marginalized sectors.

ISSUE

Whether Republic Act No. 10367 and its implementing COMELEC resolutions are unconstitutional for imposing an additional substantive requirement for voting, thereby impairing the right of suffrage and violating due process.

RULING

The Supreme Court DISMISSED the petition and declared RA 10367 and the challenged COMELEC resolutions CONSTITUTIONAL. The legal logic is anchored on the state’s compelling interest to ensure clean, honest, and credible elections. The Court ruled that biometrics registration is a procedural, not a substantive, requirement. It is a modernized method of voter identification that supports the existing substantive requirement of prior valid registration. The law does not add a new qualification for voting but establishes an enhanced system to prevent fraud like impersonation and multiple voting, thereby protecting the integrity of the electoral process.
The deactivation mechanism was deemed a reasonable regulation. The Court clarified that deactivation is not perpetual disenfranchisement; deactivated voters may apply for reactivation after complying with biometrics capture. This process aligns with the state’s regulatory power under the Constitution. Furthermore, the Court found the COMELEC’s implementation, including the extended period for validation, extensive public information drive, and the notice and hearing requirement before deactivation, satisfied due process. The measures were a valid exercise of the COMELEC’s constitutional mandate to enforce election laws, ensuring the voter list’s accuracy without unduly burdening the right to vote.