GR 193643; (January, 2013) (Digest)
G.R. No. 193643 & G.R. No. 193704; January 29, 2013
ANTONIO D. DAYAO, et al. and FEDERATION OF PHILIPPINE INDUSTRIES, INC., Petitioners, vs. COMMISSION ON ELECTIONS and LPG MARKETERS ASSOCIATION, INC., Respondents.
FACTS
Petitioners, individual LPG dealers and the Federation of Philippine Industries, Inc., filed a complaint before the Commission on Elections (COMELEC) seeking the cancellation of the party-list registration of the LPG Marketers Association, Inc. (LPGMA). They argued that LPGMA does not represent a marginalized and underrepresented sector because its members are marketers and independent re-fillers who control a significant portion of the national LPG retail market and operate businesses requiring substantial capital. They contended LPGMA is essentially a lobby group for its own business interests.
LPGMA’s petition for registration as a sectoral party-list organization had been approved by the COMELEC on January 5, 2010, following publication and hearing without any opposition. The petitioners filed their complaint for cancellation approximately four months after this approval. The COMELEC dismissed the complaint, ruling that the grounds cited were not among the exclusive statutory grounds for cancellation under Section 6 of R.A. No. 7941 (the Party-List System Act). It further held the complaint was a belated attempt to oppose the registration, which had already attained finality.
ISSUE
Whether the COMELEC committed grave abuse of discretion in dismissing the petition for cancellation of LPGMA’s party-list registration.
RULING
The Supreme Court dismissed the petitions, finding no grave abuse of discretion by the COMELEC. The Court upheld the COMELEC’s application of the doctrine of finality of judgments. The resolution approving LPGMA’s registration on January 5, 2010, became final after the reglementary period to appeal or file a motion for reconsideration lapsed without any challenge. A party-list organization’s accreditation, once final, can only be cancelled on grounds specifically enumerated in Section 6 of R.A. No. 7941, such as failure to participate in elections, failure to obtain the required percentage of votes, or violation of laws related to elections.
The petitioners’ substantive claim—that LPGMA does not represent a marginalized sector—is an attack on the factual determination made during the registration proceedings. This issue should have been raised during those proceedings or via a timely appeal. Allowing a cancellation complaint on this basis long after finality would undermine the stability of the party-list system and permit the circumvention of procedural rules. The COMELEC correctly refused to re-evaluate the concluded registration. Its dismissal was based on sound legal grounds and was therefore not tainted with grave abuse of discretion.