GR 207026; (August, 2013) (Digest)
G.R. No. 207026 ; August 6, 2013
COCOFED-PHILIPPINE COCONUT PRODUCERS FEDERATION, INC., Petitioner, vs. COMMISSION ON ELECTIONS, Respondent.
FACTS
Petitioner COCOFED, a sectoral party-list organization, manifested its intent to participate in the 2013 party-list elections but submitted only two nominees, contrary to the requirement under Section 8 of Republic Act No. 7941 for a list of not less than five. The COMELEC subsequently cancelled COCOFED’s registration and accreditation. Following the Supreme Court’s ruling in Atong Paglaum, Inc. v. COMELEC, which remanded cases for determination under new parameters, COCOFED’s case was returned to the COMELEC. The COMELEC, in its assailed May 10, 2013 Omnibus Resolution, maintained the cancellation solely due to COCOFED’s failure to submit five nominees, despite COCOFED’s later attempt to submit additional names after the elections.
ISSUE
Whether the COMELEC committed grave abuse of discretion in cancelling COCOFED’s party-list accreditation for failure to submit a list of at least five nominees.
RULING
No, the COMELEC did not commit grave abuse of discretion. The legal requirement under Section 8 of R.A. No. 7941 is clear and mandatory: a party-list group must submit a list of not less than five nominees from which representatives shall be drawn if it obtains sufficient votes. This is a substantive, not a mere formal, requirement designed to ensure transparency and voter awareness. The Court emphasized that the submission of a complete list of nominees is a precondition for participation, not a mere formality that can be remedied after the fact. The COMELEC had duly informed all parties of this requirement through its resolutions. COCOFED’s failure to comply, despite notice and opportunity during hearings, warranted the cancellation of its accreditation. The Court found that the COMELEC’s application of the law was consistent and not arbitrary, capricious, or whimsical. The subsequent submission of additional nominees after the elections and after the finality of the COMELEC’s resolution could not cure the fatal defect in its application. The petition was dismissed.