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SAMSON S. ALCANTARA, ROMEO R. ROBISO, PEDRO T. DABU, JR., LOPE E. FEBLE, NOEL T. TIAMPONG and JOSE FLORO CRISOLOGO, Petitioners, vs. COMMISSION ON ELECTIONS, JONATHAN DE LA CRUZ, ED VINCENT ALBANO and BENEDICT KATO, Respondents.
FACTS
Petitioners are officials and members of Abakada Guro Partylist (ABAKADA). Between January and April 2003, petitioners Samson S. Alcantara and others organized the party. Its name was changed to Abakada Guro Party list in 2004. In the 2007 elections, respondent Jonathan de la Cruz, as its first nominee, became the party’s sole representative in Congress. On May 5, 2009, De la Cruz tendered an “irrevocable” resignation effective December 31, 2009, but later refused to vacate his seat, prompting petitioners to file a quo warranto petition, which was dismissed as moot.
Between October and December 2009, De la Cruz requested Alcantara to convene the Supreme Assembly, as none had been held since 2004 despite the Constitution and By-Laws (CBL) requiring it every three years. Alcantara replied that it was not feasible due to funding and provincial members, suggesting it be held “early next year, as may be determined by the National Executive Board.”
On December 15, 2009, an All Leaders Assembly was convened, which Alcantara did not attend but sent a representative. This assembly resolved to hold a Supreme Assembly. On January 23, 2010, respondent Ed Vincent Albano, acting as Secretary, notified members of a Supreme Assembly on February 6, 2010. This assembly resulted in the approval of a revised CBL, the ouster and expulsion of petitioners, and the election of De la Cruz and Albano as new officers.
Petitioners filed a petition with the COMELEC to declare the February 6, 2010 meeting void, alleging it was unauthorized under the CBL as it was not called by the President or National Executive Board, that Albano had no authority, and that several participants were not legitimate members. The COMELEC Second Division dismissed the petition, finding the assembly long overdue and that respondents had “good cause” to initiate it due to petitioners’ failure to act. The COMELEC En Banc denied reconsideration, finding petitioners failed to prove the attendees were non-members, noting their membership list was from 2002-2003 and the party likely grew since then.
ISSUE
Whether the COMELEC committed grave abuse of discretion in dismissing the petition to declare the February 6, 2010 Supreme Assembly of ABAKADA null and void.
RULING
No, the COMELEC did not commit grave abuse of discretion. The petition for certiorari is dismissed.
The Supreme Court held that the COMELEC’s factual findings and application of its specialized competence in party-list matters are generally binding unless shown to be issued with grave abuse of discretion. The COMELEC correctly found that the holding of a Supreme Assembly was long overdue under the party’s CBL. Petitioners, particularly Alcantara, failed to convene the assembly despite requests, justifying the respondents’ initiative. On the membership issue, the COMELEC did not err in finding petitioners’ evidence insufficient to prove the attendees were not legitimate members, as their submitted membership list was outdated (from 2002-2003) and did not account for potential growth in membership since the party’s electoral success. The COMELEC’s conclusion that the party likely had more members by 2010 was reasonable and not arbitrary. Furthermore, internal party disputes, including questions of leadership and membership, are primarily for the party itself to resolve, and the COMELEC’s limited intervention was proper under the circumstances. No grave abuse of discretion was established.
