G.R. No. 262975, May 21, 2024
MAGKAKASAMA SA SAKAHAN, KAUNLARAN (MAGSASAKA) PARTY-LIST, REPRESENTED BY ITS SECRETARY-GENERAL, ATTY. GENERAL D. DU, PETITIONER, VS. COMMISSION ON ELECTIONS AND SOLIMAN VILLAMIN, JR., RESPONDENTS.

FACTS

This is a Petition for Certiorari under Rule 64 filed by the Magkakasama sa Sakahan Kaunlaran Party-list (Magsasaka), represented by its Secretary-General, Atty. General D. Du. The petition assails the COMELEC First Division Resolution dated November 25, 2021, and the COMELEC En Banc Resolution dated September 9, 2022. The controversy stemmed from two separate Manifestations of Intention to Participate (MIP) filed for Magsasaka for the 2022 National and Local Elections: the first filed by Atty. Du on February 8, 2021, and the second filed by Soliman Villamin, Jr. on March 29, 2021. Atty. Du and others subsequently filed petitions to deny due course to Villamin’s MIP, claiming Villamin had been ousted as the party’s National Chairperson and thus lacked authority to file the MIP. The COMELEC denied these petitions and found that Villamin had the authority to file the MIP. The ponencia reverses the COMELEC’s Resolutions, ruling that Villamin had no authority as he was validly suspended and removed. The dissenting opinion disagrees with this finding.

ISSUE

Whether the COMELEC committed grave abuse of discretion in issuing the assailed Resolutions which upheld the authority of Soliman Villamin, Jr. to file the Manifestation of Intention to Participate on behalf of Magsasaka.

RULING

The dissenting opinion finds that the COMELEC did not commit grave abuse of discretion. The opinion emphasizes that grave abuse of discretion means a capricious, whimsical, arbitrary, or despotic exercise of judgment equivalent to lack of jurisdiction, and it must be patent and gross. Errors of judgment or procedure are not correctible by certiorari. The dissenting opinion holds that the allegations and voluminous documents in the Petition fail to support a finding of grave abuse of discretion. Specifically, it addresses two points: First, the COMELEC did not deprive Magsasaka of due process by not declaring Villamin in default for belatedly filing his Answer and Joint Affidavit. The COMELEC has the discretion to liberally construe or suspend its rules in the interest of justice, and orders of default are frowned upon. Since the Answer was admitted prior to any declaration of default and there was no showing of intent to delay, the COMELEC’s action was not gravely abusive. Magsasaka was afforded every reasonable opportunity to be heard through its various pleadings. Second, the dissenting opinion implies, through its analysis of the procedural history and internal party documents referenced in the footnotes, that the COMELEC’s factual determination on Villamin’s authority was within its competence and not tainted with grave abuse. The Court should respect the COMELEC’s findings absent any grave abuse of discretion, arbitrariness, fraud, or error of law.