G.R. No. 206952, October 22, 2013
Abang Lingkod Party-List vs. Commission on Elections

FACTS

Abang Lingkod, a party-list group representing peasant farmers and fisherfolk, was registered in 2009 but failed to secure a seat in the 2010 elections. In 2012, it manifested its intent to participate in the 2013 elections. The COMELEC, pursuant to its rules and the guidelines in Ang Bagong Bayani, required previously registered groups to undergo a summary evidentiary hearing to prove continuing compliance with Republic Act No. 7941. After proceedings, the COMELEC En Banc cancelled Abang Lingkod’s registration in November 2012, finding it failed to establish a track record of uplifting its sector and that its nominees were not shown to be marginalized or advocates for the sector.
Abang Lingkod filed a petition for certiorari. While the case was pending, the Supreme Court promulgated Atong Paglaum, Inc. v. COMELEC in April 2013, which established new parameters for party-list accreditation. The Court remanded the cases of previously registered groups, including Abang Lingkod, to the COMELEC for re-evaluation under these new guidelines. However, on May 10, 2013, the COMELEC issued the assailed Resolution affirming the cancellation without conducting a new summary hearing, citing the proximity of the May 13, 2013 elections.

ISSUE

Whether the COMELEC committed grave abuse of discretion in affirming the cancellation of Abang Lingkod’s registration without conducting a summary evidentiary hearing as directed by the Supreme Court in Atong Paglaum.

RULING

Yes, the COMELEC committed grave abuse of discretion. The Supreme Court granted the petition and reversed the COMELEC’s Resolution. The legal logic is anchored on the COMELEC’s failure to comply with the Court’s directive in Atong Paglaum, which specifically ordered a fresh determination of qualifications under the new parameters. By affirming the previous cancellation without conducting the requisite summary hearing, the COMELEC effectively denied Abang Lingkod the opportunity to present evidence of its qualifications under the liberalized standards set forth in Atong Paglaum. This procedural shortcut constituted a violation of due process and an arbitrary exercise of power.
The Court emphasized that the new guidelines in Atong Paglaum significantly altered the landscape of party-list accreditation, particularly for sectoral groups. The COMELEC’s reliance on its pre-Atong Paglaum evaluation, which applied stricter, now-supplanted standards, was fundamentally erroneous. Since Abang Lingkod had obtained a status quo ante order and participated in the elections, the COMELEC was ordered to proclaim it as a winning party-list group based on its garnered votes. The COMELEC’s disregard of a direct judicial mandate to re-evaluate evidence under new rules constituted grave abuse of discretion warranting judicial correction.