G.R. No. 276456 , February 25, 2025
Partido Federal ng Pilipinas and its National President Leandro B. Verceles, Jr., and on his own behalf as a party member, Petitioners, vs. Commission on Elections, Reynaldo S. Tamayo, Jr., Thompson C. Lantion and George S. Briones, Respondents.

FACTS

Petitioners Leandro B. Verceles, Jr. and Antonio C. Rodriguez, Jr., claiming to be the newly elected National President and Secretary-General of the Partido Federal ng Pilipinas (PFP), filed an Omnibus Petition before the COMELEC to resolve an intra-party leadership dispute. They invoked Article IX-C, Section 2(5) of the 1987 Constitution and the PFP’s 2018 Constitution and By-Laws, specifically Article XVII, Section 2, which they alleged provided for a two-year term for national officers. They contended that the terms of respondents Reynaldo S. Tamayo, Jr. (President), Thompson C. Lantion (Secretary General), and George S. Briones (General Counsel) expired on September 18, 2023, creating a governance vacuum. To address this, a group of regional members convened a National Directorate Meeting on December 14, 2023, and elected Verceles and Rodriguez as new officers. They submitted a Sworn Information Update Statement (SIUS) to the COMELEC on December 20, 2023, and assailed an earlier SIUS submitted by respondent Lantion on October 4, 2023, as unlawful since his authority had allegedly expired.
Respondents Tamayo, et al., in their Comment, countered that the applicable PFP Constitution, duly submitted to the COMELEC on April 11, 2022, provides for a three-year term for national officers, making their terms valid until September 18, 2024. They argued that the petitioners’ December 2023 meeting was a “moro moro” conducted without notice, without a quorum, and without notifying key party leaders including President Ferdinand R. Marcos, Jr., the party Chairman. They further asserted that the COMELEC correctly did not act on the petitioners’ December 2023 SIUS because its attestation was falsified, as petitioner Rodriguez was not authorized by the party to submit it.
The COMELEC En Banc dismissed the petitioners’ Omnibus Petition for lack of merit. It found that the petitioners failed to prove the COMELEC’s jurisdiction over the intra-party dispute, as they did not establish that the dispute fell under the constitutional grant of power to enforce and administer laws relative to political parties. The COMELEC also ruled that the petitioners failed to exhaust intra-party remedies, noting that the PFP Constitution provides mechanisms for resolving disputes which were not utilized. Furthermore, the COMELEC found that the petitioners’ claim of a two-year term was based on an unsigned and incomplete copy of the constitution, whereas the official record contained the version with a three-year term submitted by the respondents.

ISSUE

Whether the COMELEC committed grave abuse of discretion amounting to lack or excess of jurisdiction in dismissing the petitioners’ Omnibus Petition to resolve the intra-party leadership dispute within the PFP.

RULING

No, the COMELEC did not commit grave abuse of discretion. The Supreme Court denied the Petition for Certiorari and affirmed the COMELEC’s Resolutions.
The Court held that the petitioners failed to discharge their burden of proving that the COMELEC acted with grave abuse of discretion. The COMELEC’s dismissal was based on substantial grounds: (1) the petitioners failed to establish COMELEC jurisdiction under Article IX-C, Section 2(5) of the Constitution, as they did not demonstrate that the dispute involved the enforcement of laws relative to political parties; (2) the petitioners failed to exhaust the intra-party remedies provided in the PFP Constitution before resorting to the COMELEC; and (3) the petitioners’ claim rested on an unreliable, unsigned copy of the party constitution, whereas the official COMELEC record contained the version with a three-year term for officers, which supported the respondents’ claim that their terms were still valid. The COMELEC’s factual findings, including the validity of the submitted SIUS and the applicable party constitution, are generally binding on the Court. The COMELEC’s exercise of its discretion in dismissing the petition was not done in a capricious, whimsical, or arbitrary manner.