GR 161265; (February, 2004) (Digest)
G.R. No. 161265 ; February 24, 2004
LABAN NG DEMOKRATIKONG PILIPINO, represented by its Chairman EDGARDO J. ANGARA vs. THE COMMISSION ON ELECTIONS and AGAPITO A. AQUINO
FACTS
The Laban ng Demokratikong Pilipino (LDP), represented by its Chairman Senator Edgardo Angara, filed a petition with the COMELEC. It sought recognition that only Angara or his authorized representatives could validly endorse the certificates of candidacy and nomination for the party’s official candidates in the 2004 elections. This request stemmed from an internal party dispute, as Angara had placed the Secretary General, Representative Agapito Aquino, on indefinite forced leave and designated an Acting Secretary General. Aquino contested this action, arguing the Chairman lacked such disciplinary authority. Despite the internal conflict, Aquino proceeded to sign and file a Certificate of Nomination for Senator Panfilo Lacson as the LDP presidential candidate.
ISSUE
The core issue is whether the COMELEC correctly resolved the intra-party leadership dispute by allowing both factions to nominate candidates under the LDP banner.
RULING
The Supreme Court reversed the COMELEC’s resolution. The COMELEC, in an attempt to avoid interfering in an internal party affair, had issued a ruling that effectively “split the baby” by allowing both the Angara faction and the Aquino faction to submit nominations, with the COMELEC accepting all such documents. The Court held this was a grave abuse of discretion. While the COMELEC is generally barred from interfering in intra-party leadership disputes, it has a ministerial duty under election laws to recognize only the official candidates of a registered political party. By allowing two conflicting sets of nominations, the COMELEC created confusion and effectively permitted the party to have multiple official candidates for the same position, which is legally untenable. The Court emphasized that the COMELEC’s role includes ensuring that the person filing a certificate of candidacy under a party’s name is the bona fide nominee of that party. Its resolution failed to discharge this duty and instead sanctioned a situation that would lead to electoral chaos, violating its constitutional mandate to enforce and administer election laws.