G.R. No. L-47883, March 25, 1978
Lakas ng Bayan (LABAN), petitioner, vs. Commission on Elections & Nacionalista Party, respondents.

FACTS

The case arose from the preparations for the April 7, 1978, Interim Batasang Pambansa elections. Petitioner Lakas ng Bayan (LABAN) filed a certiorari and prohibition petition challenging certain actions and resolutions of the Commission on Elections (COMELEC). LABAN alleged that the Nacionalista Party, which had entered into a coalition with the Kilusan ng Bagong Lipunan (KBL), was accorded undue advantages. These included potentially double the allowed campaign spending, double advertising spaces in media, and entitlement to six watchers per voting center (three from each party) compared to only three for LABAN.
LABAN contended this created an unconstitutional imbalance. The COMELEC, through Resolution No. 1929 dated March 4, 1978, subsequently issued rules to govern political parties with common candidates. The resolution stipulated that such coalitions could only jointly spend up to the statutory limit per voter, jointly purchase airtime and advertising space not exceeding that allotted to single parties, and were entitled to appoint only three common watchers per voting center collectively.

ISSUE

The primary issue was whether the COMELEC acted with grave abuse of discretion in its treatment of the coalition between the Nacionalista Party and the KBL, and whether the subsequently promulgated Resolution No. 1929 adequately cured the alleged infirmities.

RULING

The Court, through the main decision penned by Justice Barredo, dismissed the petition. The legal logic centered on the COMELEC’s constitutional mandate to enforce and administer all laws relative to the conduct of elections. The Court found that the alleged discriminatory practices were effectively remedied by COMELEC Resolution No. 1929. This resolution leveled the playing field by imposing aggregate spending limits for coalitions, restricting their combined media access to that of a single party, and limiting them to three shared watchers.
The ruling emphasized the COMELEC’s proactive role in adjusting its directives to correct inequities, thereby negating any finding of grave abuse of discretion. The Court deferred to the COMELEC’s expertise in implementing election laws to ensure free, orderly, and honest elections. Justice Fernando, in a separate concurring and dissenting opinion, agreed with the dismissal but argued for an additional instruction to the COMELEC to count votes containing only the words “Lakas” or “Bayan” as votes for the full LABAN slate, to protect the fundamental right of suffrage from technical nullification. This view, however, did not alter the main disposition. The petition was dismissed for lack of merit.