G.R. No. 188920 , February 16, 2010
JOSE L. ATIENZA, JR., MATIAS V. DEFENSOR, JR., RODOLFO G. VALENCIA, DANILO E. SUAREZ, SOLOMON R. CHUNGALAO, SALVACION ZALDIVAR-PEREZ, HARLIN CAST-ABAYON, MELVIN G. MACUSI and ELEAZAR P. QUINTO, Petitioners, vs. COMMISSION ON ELECTIONS, MANUEL A. ROXAS II, FRANKLIN M. DRILON and J.R. NEREUS O. ACOSTA, Respondents.

FACTS

This case involves a leadership dispute within the Liberal Party (LP). On July 5, 2005, respondent Franklin M. Drilon, then LP president, announced the party’s withdrawal of support from President Arroyo. Petitioner Jose L. Atienza, Jr., LP Chairman, and others denounced this move. On March 2, 2006, Atienza hosted an assembly that declared all LP ruling body positions vacant and elected new officers, with Atienza as president. Drilon filed a petition with the COMELEC to nullify this election. The COMELEC annulled the March 2, 2006 elections and held Drilon served in a holdover capacity. The Supreme Court, in a prior resolution, upheld the COMELEC’s jurisdiction, found the LP Constitution validly amended, and ruled Drilon’s term would end on November 30, 2007. Subsequently, before Drilon’s term expired, the LP’s National Executive Council (NECO) met and elected respondent Manuel A. Roxas II as the new LP president. Petitioners (Atienza et al.) filed a petition before the COMELEC seeking to enjoin Roxas from assuming the presidency, claiming the NECO assembly was invalidly convened due to quorum issues and an improper membership list. They also complained that Atienza was not invited and some members were treated as “guests.” Respondents (Roxas et al.) countered that the election complied with the amended LP Constitution, that NECO membership changed due to supervening events like deaths, resignations, and the results of the May 2007 elections, and that some petitioners were deemed resigned or had forfeited membership for running under other parties. The COMELEC denied petitioners’ petition, noting the NECO composition changed after the May 2007 elections and treating the expulsion of petitioners as an internal party matter beyond its jurisdiction. Petitioners filed this certiorari petition without a motion for reconsideration.

ISSUE

1. Whether the LP is an indispensable party not impleaded.
2. Whether petitioners, as ousted members, have legal standing to question Roxas’ election.
3. Whether the COMELEC gravely abused its discretion in upholding the NECO membership that elected Roxas.
4. Whether the COMELEC gravely abused its discretion by resolving the NECO meeting validity without first resolving the validity of petitioners’ expulsion.
5. Whether respondents violated petitioners’ constitutional right to due process by their expulsion from the party.

RULING

1. No, the LP is not an indispensable party. The causes of action are directed against the individual respondents (Roxas, Drilon, Acosta) for their alleged despotic acts in disenfranchising petitioners and railroading the election. No wrong was imputed to the LP, nor was affirmative relief sought from it.
2. Yes, petitioners have legal standing. Applying the “real party-in-interest” rule, petitioners allege they were irregularly expelled and excluded from the election. If these allegations are true, they stand to be injured by the judgment and are entitled to seek relief for recognition as members and for a new election.
3. No, the COMELEC did not gravely abuse its discretion. The amended LP Constitution provides that incumbent senators, House members, governors, and mayors are NECO members. The May 2007 elections necessarily altered the NECO’s composition. Petitioners failed to prove the NECO was improperly convened. The COMELEC’s finding was based on substantial evidence.
4. No, the COMELEC did not gravely abuse its discretion. The issue of the NECO meeting’s validity is separate from the issue of expulsion. The COMELEC correctly treated the expulsion as an internal party matter relating to discipline, over which it has no jurisdiction. Resolving the NECO meeting’s validity did not require prior resolution of the expulsion issue.
5. The Court did not rule on the merits of the due process claim regarding expulsion. It held that the expulsion of members by a political party is an internal party affair. The COMELEC’s jurisdiction over political parties is limited to adjudicating factional disputes involving their nomination of official candidates. Disciplinary actions against members fall outside this limited jurisdiction. Therefore, the COMELEC correctly refrained from ruling on the validity of the expulsion.