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 criteria for accrediting political parties as the dominant majority and dominant minority parties for the May 13, 2019 elections. The Liberal Party (LP) filed a petition for accreditation as the dominant minority party. On May 8, 2019, the COMELEC En Banc issued Resolution No. 10538, declaring the Nacionalista Party (NP) as the dominant minority party and the LP as one of the major political parties. The LP filed a Petition for Certiorari, arguing that the COMELEC committed grave abuse of discretion by ignoring the legal definition of a “dominant minority party” as an opposition party. The LP contended that the NP, being part of the ruling coalition, could not be considered a minority or opposition party. The elections having concluded, the LP also sought a ruling to guide future conduct.

ISSUE

Did the COMELEC commit grave abuse of discretion in accrediting the Nacionalista Party as the dominant minority party for the 2019 national and local elections?

RULING

No, the COMELEC did not commit grave abuse of discretion. The Supreme Court dismissed the petition. The Court emphasized that the COMELEC possesses broad constitutional and statutory powers to enforce election laws, which includes the authority to promulgate rules for determining dominant parties. The criteria enumerated in COMELEC Resolution No. 10514 were based on factors like past electoral performance, number of incumbent officials, organizational strength, and ability to field a complete slate, which are derived from and consistent with Section 26 of Republic Act No. 7166 . The COMELEC applied these objective criteria and a points system, finding that the NP scored higher than the LP in several categories. The Court ruled that the COMELEC’s determination was a valid exercise of its rule-making and administrative discretion. The petitioner’s argument—that “minority” must strictly mean the political opposition—was not sustained. The Court found that the COMELEC’s interpretation and application of its own rules were neither arbitrary, capricious, nor issued with grave abuse of discretion. Absent a clear showing of such abuse, which equates to a jurisdictional error, the Court will not substitute its judgment for that of the COMELEC on matters within its expertise. The petition, being moot due to the conclusion of the 2019 elections, was also dismissed on that ground, though the Court addressed the substantive issue to provide guidance.