Alliance for Nationalism and Democracy v. Commission on Elections
REITERATIONFacts
The Antecedents: The Commission on Elections (COMELEC) En Banc, in a Resolution dated 7 November 2012, canceled the Certificate of Registration and/or Accreditation of petitioner Alliance for Nationalism and Democracy (ANAD). The grounds cited were: (I) ANAD's failure to belong to the marginalized and underrepresented sectors enumerated in Section 5 of R.A. No. 7941; (II) lack of proof that nominees Arthur J. Tariman and Julius D. Labandria were nominated by ANAD, and that ANAD only submitted three nominees, failing to comply with Section 4, Rule 3 of Resolution No. 9366; and (III) ANAD's failure to submit its Statement of Contributions and Expenditures for the 2007 National and Local Elections as required by Section 14 of Republic Act No. 7166. Procedural History: ANAD challenged the COMELEC's resolution before the Supreme Court. The Court, in Atong Paglaum, Inc. v. Comelec, remanded the case to the COMELEC for re-evaluation. Subsequently, in a Resolution dated 11 May 2013, the COMELEC affirmed the cancellation of ANAD's registration and disqualified it from participating in the 2013 Elections, citing its failure to submit at least five nominees and its failure to submit its Statement of Contributions and Expenditures for the 2007 Elections. The Petition: ANAD filed a Petition for Certiorari with Urgent Prayer for the Issuance of a Temporary Restraining Order and Writ of Mandamus, seeking to compel the COMELEC to canvass the votes cast for it. ANAD argued that the COMELEC gravely abused its discretion by promulgating the assailed Resolution without a summary evidentiary hearing, violating its right to due process, and that the COMELEC erred in finding that it submitted only three nominees and failed to submit its Statement of Contributions and Expenditures.
Issue(s)
Whether or not the COMELEC gravely abused its discretion in promulgating the assailed Resolution without the benefit of a summary evidentiary hearing mandated by the due process clause. Whether or not the COMELEC erred in finding that petitioner submitted only three nominees and that it failed to submit its Statement of Contributions and Expenditures in the 2007 Elections.
Ruling
The petition is dismissed. The Court finds no grave abuse of discretion on the part of the Commission on Elections.
Ratio Decidendi
On the issue of grave abuse of discretion and the lack of a summary evidentiary hearing: The Court held that ANAD was afforded a summary hearing on 23 August 2013, during which its president authenticated documents and answered questions. The Court found no need for another hearing after the case was remanded, as the COMELEC could resort to previously submitted documents and evidence to re-evaluate ANAD's qualifications. It is presumed that the qualifications, or lack thereof, established during the initial hearing continued until election day. The Court reiterated that for a petition for certiorari to prosper, there must be a clear showing of caprice and arbitrariness in the exercise of discretion, which was not demonstrated by ANAD. On the issue of COMELEC's findings regarding nominees and the Statement of Contributions and Expenditures: The Court affirmed the COMELEC's factual findings, emphasizing that the COMELEC, as a specialized agency tasked with supervising elections, has factual findings and conclusions that should not be interfered with by the Court absent grave abuse of discretion or jurisdictional infirmity. The Court noted that ANAD submitted only three nominees, violating Section 8 of R.A. No. 7941, which requires at least five nominees and prohibits substitution after submission. Furthermore, ANAD failed to submit a proper Statement of Contributions and Expenditures for the 2007 Elections, as required by COMELEC Resolution No. 9476, submitting incomplete documents. The Court stressed that the COMELEC's findings on these matters were based on evidence presented and were not contested or rebutted by ANAD. The Court also reiterated the principle that factual findings of administrative bodies, especially the COMELEC, are given great weight and will not be disturbed unless there is absolutely no evidence or substantial evidence to support them.
Main Doctrine
The Commission on Elections (COMELEC) did not commit grave abuse of discretion in canceling the Certificate of Registration and/or Accreditation of ANAD for failure to comply with the minimum number of nominees and for non-submission of its Statement of Contributions and Expenditures, as these are mandatory requirements under election laws. The COMELEC, as a specialized agency, is presumed to have acted correctly within its competence, and its factual findings are given great weight.