Quebal, Ace Dominic T.
ELECTION LAW
LIBERAL PARTY V COMELEC
Facts:
1. The COMELEC released resoulution No. 8646 to
set the deadline for the submission of petitions
for registration of political parties for the May
2010 electoins
a. Said deadline was set on August 17, 2009
2. However, despite the deadline, the NP and NPC,
two separate political parties, who intended to
form a coalition, only filed their petition on
February 12, 2009
a. They contend that they do not fall under
the deadline because Coalition is not
mentioned in the resolution
3. The COMELEC granted the petition
4. Hence, this case by the LP
Issue:
1. WON a collation comes within the definition of
a political party so as to apply the deadline set
by the COMELEC for the submission of petitions
for registration of political parties to the former -
YES
Held:
1. Yes. Admittedly, Resolution No. 8646 simply
states that August 17, 2009 is the [L]ast day
for filing petitions for registration of political
parties, without mentioning organizations and
coalitions in the way that the three entities are
separately mentioned under Section 2(5), Article
IXC of the Constitution and Rule 32, Section 1 of
the COMELEC Rules. Resolution No. 8646,
however, is simply a listing of electoral activities
and deadlines for the May 10, 2010 elections it
is not in any way a resolution aimed at
establishing distinctions among political
parties, organizations, and coalitions.
a. In the absence of any note, explanation or
reason why the deadline only mentions
political parties, the term political
parties should be understood in its
generic sense that covers political
organizations and political coalitions as
well. To rule otherwise is to introduce,
through a COMELEC deadlinesetting
resolution, a meaning or intent into
Section 2(5), Article IXC, which was not
clearly intended by the Constitution or by
the COMELEC Rules Resolution No. 8646
would effectively differentiate between
political parties, on the one hand, and
political organizations and coalitions, on
the other
b. We solely rule for now that the en banc
gravely abused its discretion when it
disregarded its own deadline in ruling on
the registration of the NPNPC as a
coalition. In so ruling, we emphasize that
the matter of party registration raises
Quebal, Ace Dominic T.
ELECTION LAW

critical election concerns that should be be at its most strict in implementing and
handled with discretion commensurate complying with the standards and
with the importance of elections to our procedures the Constitution and our laws
democratic system. The COMELEC should impose.