G.R. No. 247645 , July 26, 2022
LIBERAL PARTY, REPRESENTED BY ITS PRESIDENT, FRANCIS N. PANGILINAN, AND/OR ITS SECRETARY GENERAL, JOSE CHRISTOPHER Y. BELMONTE, PETITIONER, VS. COMMISSION ON ELECTIONS AND NACIONALISTA PARTY, REPRESENTED BY ITS PRESIDENT, MANUEL B. VILLAR, AND/OR ITS SECRETARY GENERAL, ALAN PETER CAYETANO, RESPONDENTS.

FACTS

The Commission on Elections (COMELEC) issued Resolution No. 10514, establishing guidelines for accrediting the dominant majority and minority parties for the May 13, 2019 National and Local Elections. The Liberal Party (LP) filed a petition for accreditation as the dominant minority party. However, the COMELEC, via Resolution No. 10538 dated May 8, 2019, instead accredited the Nacionalista Party (NP) as the dominant minority party and listed LP among the eight major national parties. LP filed a Petition for Certiorari before the Supreme Court, arguing that the COMELEC committed grave abuse of discretion. LP contended that under Section 27 of the Omnibus Election Code, a minority party must be one that stands in opposition to the majority. Since NP was part of the ruling coalition, LP asserted it could not be considered a minority party. The petition sought to annul the COMELEC resolution and to have the Court establish clear guidelines for future accreditations.

ISSUE

Whether the Supreme Court should grant the Petition for Certiorari assailing the COMELEC’s accreditation of the Nacionalista Party as the dominant minority party for the 2019 elections.

RULING

The Petition is dismissed. The case has been rendered moot and academic by the supervening conclusion of the May 13, 2019 National and Local Elections. The purpose of the accreditation—to designate parties for specific privileges like official watchers during those specific elections—had already been fulfilled. Any ruling by the Court on the validity of Resolution No. 10538 would produce no practical legal effect. The general rule is that courts decline jurisdiction over moot cases.
While exceptions exist, such as when the case is capable of repetition yet evading review, or when it involves a grave constitutional violation, none apply here. The ponencia (main opinion) correctly found that the issues presented do not fall under these recognized exceptions. Consequently, the Court was not compelled to rule on the substantive merits of LP’s arguments regarding the COMELEC’s interpretation of a “minority party” or its exercise of rule-making power. Justice Caguioa, in his Separate Concurring Opinion, emphasized that since the dismissal is squarely based on mootness, any substantive discussion by the ponencia on the correctness of the COMELEC’s criteria or guidelines is merely obiter dictum (non-binding commentary). Such discussion cannot serve as a controlling precedent for future cases. The petition was dismissed solely because it presented no live, justiciable controversy for the Court to resolve.