AI-generated
Updated 25th February 2025
Dayao vs. Commission on Elections
The Supreme Court dismissed petitions for certiorari seeking the annulment of COMELEC resolutions that denied the cancellation of LPGMA's party-list registration, affirming that the COMELEC's decision to grant registration to a party-list group can become final and conclusive, barring subsequent challenges unless new grounds for cancellation arise post-registration.

Primary Holding

The Supreme Court held that the COMELEC did not commit grave abuse of discretion in dismissing the complaint for cancellation of LPGMA's registration, as the grounds for cancellation were not among those listed in the Party-List System Act, and the complaint was essentially a belated opposition to the registration.

Background

Petitioners, who are dealers of LPG and an association of industries, sought to cancel the registration of LPGMA as a sectoral organization under the Party-List System, arguing that LPGMA did not represent a marginalized sector.

History

  • January 5, 2010: COMELEC First Division approved LPGMA's registration.

  • April 12, 2010: Petitioners filed a complaint for cancellation of LPGMA's registration.

  • August 5, 2010: COMELEC First Division dismissed the complaint.

  • September 6, 2010: COMELEC En Banc denied reconsideration.

  • January 29, 2013: Supreme Court issued its decision.

Facts

  • 1. LPGMA, an association of consumers and small industry players in the LPG sector, sought party-list accreditation to participate in the 2010 elections. After approval, petitioners challenged this registration, claiming LPGMA did not represent a marginalized sector due to its members' significant market share and business interests.

Arguments of the Petitioners

  • 1. LPGMA does not represent a marginalized sector as its members are not underrepresented but rather control a significant portion of the LPG market.
  • 2. The complaint for cancellation was validly filed under Section 6 of RA 7941.

Arguments of the Respondents

  • 1. The Constitution does not require party-list representatives to be from marginalized sectors.
  • 2. The grounds cited by petitioners for cancellation are not listed in Section 6 of RA 7941.
  • 3. The complaint was a belated opposition to registration, which had already become final.

Issues

  • 1. The Constitution does not require party-list representatives to be from marginalized sectors.
  • 2. The grounds cited by petitioners for cancellation are not listed in Section 6 of RA 7941.
  • 3. The complaint was a belated opposition to registration, which had already become final.

Ruling

  • 1. The Supreme Court ruled that the COMELEC's decision to grant registration to LPGMA was final and could not be disturbed without new grounds for cancellation arising post-registration. The complaint was dismissed as it was essentially a late opposition to registration.

Doctrines

  • 1. Finality of Administrative Decisions: Decisions of administrative bodies like COMELEC can become final and executory.
  • 2. Party-List System: The system aims to enable marginalized and underrepresented sectors to participate in legislative processes.

Precedents Cited

  • 1. Ang Bagong Bayani-OFW Labor Party v. COMELEC: Cited for guidelines on party-list representation.
  • 2. Bello v. COMELEC: Cited to confirm the COMELEC's power to cancel party-list registration.

Statutory and Constitutional Provisions

  • 1. Section 6, RA 7941 (Party-List System Act).
  • 2. Section 2(5), Article IX-C of the 1987 Constitution.