Duterte Youth Party-List vs. Commission on Elections

The deadlines set by COMELEC for the substitution of party-list nominees are mandatory even after the elections because the timing of substitution is a matter of substance—not mere form—that directly affects the electorate's constitutional right to information on matters of public concern, enabling voters to make intelligent and informed choices. The COMELEC's approval of a post-election substitution beyond its own deadline and with undue haste, particularly involving a former commissioner, constitutes grave abuse of discretion.

P3PWD Party-List filed its Petition for Registration and Accreditation as a regional sectoral organization under the party-list system on March 23, 2021. On October 6, 2021, it submitted its initial list of five nominees to the COMELEC Law Department. On November 5, 2021—within the November 15, 2021 deadline set by COMELEC Resolution No. 10717—P3PWD substituted its second to fifth nominees, publishing the new list on November 6, 2021. The COMELEC En Banc approved this substitution on November 24, 2021. In the May 9, 2022 elections, P3PWD garnered 391,174 votes (1.0629% of total party-list votes), entitling it to one seat in the House of Representatives. First nominee Grace S. Yeneza was proclaimed and took her oath on May 30, 2022. Between June 7 and June 10, 2022, all five nominees resigned—the second to fifth nominees citing personal reasons or providing no reason at all, and first nominee Yeneza citing her daughter's cancer diagnosis. On June 14, 2022, P3PWD filed documents substituting its nominees with a new list headed by Ma. Rowena Amelia V. Guanzon, who had retired as COMELEC Commissioner on February 2, 2022.

• The Parties: Petitioner Duterte Youth Party-List is a party-list organization that participated in the 2022 National and Local Elections. It is represented by Chairperson Ronald Gian Carlo L. Cardema and Representative Ducielle Marie S. Cardema. Respondent P3PWD Party-List is a regional sectoral organization representing the rights and interests of patients, persons with disabilities, and senior citizens. Respondent Ma. Rowena Amelia V. Guanzon is a former COMELEC Commissioner who served until her retirement on February 2, 2022.

• P3PWD's Registration and Initial Nominees: On March 23, 2021, P3PWD filed a Petition for Registration and Accreditation. Its registration was approved during the incumbency of then-Commissioner Guanzon. On October 6, 2021, P3PWD submitted its initial five nominees: Grace S. Yeneza (1st), Joel R. Lopez (2nd), Allen Jose R. Serna (3rd), Michelle R. Ofalla (4th), and Guillermo R. Eugenio (5th).

• First Substitution (Within Deadline): On November 5, 2021—within the November 15, 2021 deadline set by COMELEC Resolution No. 10717—P3PWD filed a withdrawal with substitution of its second to fifth nominees, publishing the new list on November 6, 2021. The new nominees were: Grace S. Yeneza (retained 1st), Ira Paulo A. Pozon (2nd), Marianne Heidi C. Fullon (3rd), Peter Jonas R. David (4th), and Lily Grace A. Tiangco (5th). The COMELEC En Banc approved this substitution on November 24, 2021.

• 2022 Elections and Proclamation: P3PWD participated in the May 9, 2022 elections and garnered 391,174 votes (1.0629%), entitling it to one seat. On May 26, 2022, the COMELEC NBOC proclaimed P3PWD entitled to one seat and proclaimed first nominee Yeneza as representative. Yeneza took her oath on May 30, 2022, and copies of her Certificate of Proclamation and Oath of Office were furnished to the House of Representatives.

• En Masse Resignation of All Five Nominees: Between June 7 and June 10, 2022, all five nominees resigned: Second nominee Pozon resigned on June 7, 2022, for "personal reasons." Third nominee Fullon resigned on June 9, 2022, without stating any reason. Fourth nominee David resigned on June 9, 2022, for "personal reasons." Fifth nominee Tiangco resigned on June 9, 2022, to assist her husband in their businesses. First nominee Yeneza resigned on June 10, 2022, stating she needed to care for her daughter diagnosed with stage 3 cancer in December 2021. The mass resignation was reported by news organizations on June 14, 2022.

• Second Substitution (Post-Election): On June 14, 2022, P3PWD filed before the COMELEC Law Department the documents for withdrawal and substitution, including Board Resolution No. 2022-02 accepting resignations and substituting new nominees, notarized resignation letters, and Certificates of Nomination and Acceptance for the substitute nominees: Ma. Rowena Amelia V. Guanzon (1st), Rosalie J. Garcia (2nd), Cherrie B. Belmonte-Lim (3rd), Donnabel C. Tenorio (4th), and Rodolfo B. Villar, Jr. (5th). Guanzon had become a member of P3PWD on February 4, 2022, merely two days after her retirement from the COMELEC.

• COMELEC Approval: On June 15, 2022, the COMELEC En Banc issued Minute Resolution No. 22-0774 (by a vote of 3-1) adopting the Law Department's recommendation to approve the withdrawal and give due course to the new list, subject to compliance with the publication requirement. Commissioners Inting, Casquejo, and Bulay voted to approve; Commissioner Ferolino voted to defer. On June 17, 2022, P3PWD filed a Manifestation submitting proof of publication in two national newspapers on June 15 and 17, 2022.

• Duterte Youth's Opposition and Petition: On June 17, 2022, Duterte Youth filed a Verified Opposition arguing the substitution was filed beyond COMELEC deadlines and violated Republic Act Nos. 3019 and 6713 because Guanzon was a recent COMELEC member. Without awaiting resolution of the Opposition and without an official copy of Resolution No. 22-0774, Duterte Youth filed its Petition before the Supreme Court on June 21, 2022.

• Subsequent COMELEC Actions and Proclamation: On June 22, 2022, the COMELEC En Banc issued Minute Resolution No. 22-0798 noting P3PWD's compliance with the publication requirement, and Minute Resolution No. 22-0810 denying the Opposition for lack of merit. On the same day, the COMELEC NBOC proclaimed Guanzon as the qualified nominee of P3PWD. Guanzon took her oath before CA Associate Justice Sorongon on June 23, 2022, and submitted her oath to the HOR on June 27, 2022.

• Supreme Court TRO: On June 29, 2022, the Supreme Court issued a TRO enjoining the COMELEC from implementing the assailed resolution and the HOR from allowing Guanzon and other substitutes to assume office. Despite the TRO, Guanzon filed House Bill No. 440 on June 30, 2022. The HOR later manifested it would comply with the TRO and returned Guanzon's draft measures.

• Guanzon's Pre-Withdrawal Statements: On May 14, 2022—before the other nominees resigned—Guanzon posted a Facebook livestream stating that Yeneza was considering resigning and that she would substitute, saying "talagang uupo ako diyan." During the campaign period, on March 29, 2022, Guanzon had posted an Instagram reel campaigning as "kandidato ng P3PWD Party-List."

• Standing: Duterte Youth argued it had standing as the playing field among party-list organizations became unequal when the COMELEC granted substitution beyond its deadline. The Cardemas invoked standing as concerned citizens, taxpayers, registered voters, and legislator (Ducielle Cardema), asserting the transcendental importance of the constitutional questions raised.

• Proper Remedy: The petition for certiorari under Rule 64 in relation to Rule 65 was proper because the COMELEC acted in the exercise of quasi-judicial functions when it resolved the Opposition, citing Aggabao v. COMELEC. No plain, speedy, and adequate remedy existed since the COMELEC Rules do not provide for motions for reconsideration of En Banc rulings on substitution.

• HRET Jurisdiction: Jurisdiction remained with the COMELEC because Guanzon had not assumed office as representative due to the Court's TRO enjoining the HOR from allowing her to assume office.

• Validity of Voting: The assailed Resolutions were void for not having been approved by at least four members of the COMELEC, the minimum required under Article IX-A, Section 7 of the Constitution, as interpreted by prevailing jurisprudence.

• Invalidity of Substitution: The COMELEC committed grave abuse of discretion in approving the substitution beyond its deadline, violating the people's constitutional right to information on matters of public concern. Allowing all five nominees to withdraw simultaneously after elections and installing five new nominees defeats the electorate's right to know who their representatives will be and amounts to fraud.

• Guanzon's Disqualification: Guanzon was not eligible as a substitute nominee because she was a COMELEC Commissioner at the time of P3PWD's registration approval, and her substitution violated Republic Act Nos. 3019 and 6713.

• Contempt Charge (G.R. No. 261876): Duterte Youth argued that despite knowledge of the TRO, Guanzon violated it by filing bills, distributing equipment bearing the title "CONG," posting about her office as representative, publicly declaring she must be addressed as "Cong" or "Congresswoman," and posting that the TRO was moot.

• Standing: The COMELEC and P3PWD contended that Duterte Youth failed to demonstrate a present substantial interest. The Cardemas' alleged injury was too abstract; they would not be deprived of a seat even if P3PWD's nominee sat. Their standing as taxpayers, voters, and legislator was unsubstantiated.

• Nature of COMELEC Function: The COMELEC argued the assailed Resolutions were issued in the exercise of administrative functions—the receipt and approval of Certificates of Nomination and Acceptance—beyond the ambit of Rule 65. The filing of an Opposition did not convert the proceedings to quasi-judicial; no legal controversy requiring adjudication of conflicting rights arose.

• Alternative Remedy: By filing a Petition to Deny Due Course under COMELEC Resolution No. 9366, petitioner recognized that a plain, speedy, and adequate remedy was available.

• HRET Jurisdiction: P3PWD argued that Guanzon duly assumed office on June 30, 2022, and the TRO's dispositive portion addressed only the COMELEC, not the HOR. Thus, Guanzon was an incumbent member whose title is assailable only before the HRET.

• Validity of Substitution: The deadlines in COMELEC Resolutions apply only before elections; after elections, they are merely directory, citing Engle v. COMELEC. Section 16 of R.A. No. 7941 allows the submission of additional nominees when the list is exhausted, and Section 8 permits withdrawal of nominations. Petitioner Duterte Youth itself previously sought and obtained post-election substitution of its nominees in 2019, which the Court upheld in Angcos v. Duterte Youth.

• Voting Threshold: The majority vote requirement in Article IX-A, Section 7 applies only to quasi-judicial functions. For administrative matters, Section 2 of Resolution No. 9936 governs, requiring only a majority of commissioners present at a meeting with a quorum.

• No Grave Abuse of Discretion: The COMELEC ministerially approved the substitution and must be given considerable latitude in adopting means to promote free, orderly, and honest elections. Guanzon's status as former commissioner does not automatically taint the resolution.

• Contempt Defense (G.R. No. 261876): Guanzon argued she could not violate a TRO not addressed to her. She had no actual knowledge of the TRO's contents when she filed the bill on June 30, 2022. Her public statements were fair responses to the Cardemas' media comments and were made without intent to impede the administration of justice.

• Standing: Whether petitioner Duterte Youth Party-List possessed legal standing to question the assailed COMELEC Minute Resolutions.

• Proper Remedy: Whether a petition for certiorari under Rule 64 in relation to Rule 65 was the proper remedy from the assailed Minute Resolutions.

• Nature of COMELEC Function: Whether the COMELEC issued the assailed Minute Resolutions in the exercise of its quasi-judicial or administrative functions.

• Voting Requirement: Whether the assailed Minute Resolutions were void for not having been approved by at least four members of the COMELEC under Article IX-A, Section 7 of the Constitution.

• HRET Jurisdiction: Whether jurisdiction remained with the COMELEC or was acquired by the House of Representatives Electoral Tribunal.

• Prematurity: Whether the petition was prematurely filed without awaiting resolution of the Opposition.

• Applicable Law: Whether Section 8 or Section 16 of Republic Act No. 7941 governs the post-election substitution of party-list nominees.

• Mandatory Nature of Deadlines: Whether COMELEC Resolution No. 10690's deadlines for substitution of party-list nominees are mandatory even after the elections.

• COMELEC Rule-Making Power: Whether the COMELEC may impose a deadline for substitution of nominees when the law itself does not impose one or expressly empower the COMELEC to do so.

• Grave Abuse of Discretion: Whether the COMELEC committed grave abuse of discretion in approving the post-election substitution of P3PWD's nominees.

• Sub Judice Contempt: Whether Guanzon should be cited in contempt for violation of the sub judice rule based on her public comments on the Court's TRO.

• TRO Violation Contempt: Whether Guanzon should be cited in indirect contempt for violating the Court's June 29, 2022 TRO.

• Standing: Duterte Youth failed to show direct injury from the COMELEC's approval of the substitution, as it admitted during oral arguments that it would not be deprived of a seat. Its allegation of an uneven playing field was too abstract. Standing as taxpayers failed because no illegal disbursement of public funds had occurred. Standing as legislators and voters was likewise unsubstantiated. However, given the transcendental importance of the constitutional questions raised—involving the people's right to information on matters of public concern in the election of party-list organizations—petitioner was accorded standing as a concerned citizen, consistent with Akbayan Citizens Action v. Aquino.

• Proper Remedy: The assailed Resolutions were issued in the exercise of the COMELEC's administrative functions, making Rule 64 inapplicable. However, the Court treated the petition as one filed under Rule 65 in the interest of substantial justice. The filing of a Petition to Deny Due Course was not a plain, speedy, and adequate remedy because its ground—material misrepresentation—differed from the grounds raised in the present Petition (violation of deadlines and anti-graft laws). The COMELEC Rules prohibit motions for reconsideration of En Banc rulings except in election offense cases.

• Nature of COMELEC Function: The COMELEC acted in the exercise of its administrative—not quasi-judicial—functions. The approval of substitution merely called for enforcement of election laws and rules without exercising discretionary authority or adjudicatory power. Unlike in Aggabao, the Opposition here did not create a legal controversy involving conflicting rights of parties. The existence of an opposition does not automatically convert a proceeding to quasi-judicial; a conflict between an alleged right and a general interest in law enforcement is not a conflict of rights.

• Voting Requirement: Since the assailed Resolutions were issued in the exercise of administrative functions, Article IX-A, Section 7's requirement of a majority vote of all members did not apply. Section 2 of COMELEC Resolution No. 9936 governed, requiring only a majority of all commissioners present at a meeting with a quorum. The three-to-one vote was valid.

• HRET Jurisdiction: Jurisdiction remained with the COMELEC because Guanzon did not assume office. While the dispositive portion of the TRO did not explicitly mention the HOR, the body of the TRO demonstrated the Court's intent to enjoin both the COMELEC and the HOR. Sans conflict between the body and the fallo, the TRO must be read in its entirety. The HOR manifested compliance with the TRO and confirmed Guanzon had not been enrolled as a member.

• Prematurity: The filing of the Opposition was not a condition sine qua non to filing a petition for certiorari. The COMELEC Rules prohibit motions for reconsideration of En Banc rulings except in election offense cases. The Petition was not premature.

• Applicable Law: Section 8 of R.A. No. 7941, as implemented by COMELEC Resolutions, governs—not Section 16. Section 16 applies only to a vacancy in a party-list seat during the term (from noon of June 30 following the election). Since P3PWD's seat did not legally exist prior to noon of June 30, 2022, the en masse resignation could not have caused a vacancy under Section 16. The substitution occurred prior to June 30, 2022, placing it under Section 8.

• Mandatory Nature of Deadlines: Rules and regulations governing the substitution of party-list nominees are mandatory even after elections. The doctrine that election rules are directory after elections, as stated in Engle v. COMELEC, refers only to matters of form and cannot be applied to substantial qualifications. The timing of substitution is a matter of substance, not form, because it affects the electorate's right to know the identities of nominees to make an intelligent and informed choice. A contrary rule would incentivize parties to field nominees with no bona fide intention to serve and reduce elections to a "mere sport where players may be substituted at will or on a whim."

• COMELEC Rule-Making Power: The COMELEC is empowered to impose deadlines for substitution of nominees to carry out the purposes of R.A. No. 7941, consistent with its duty to promulgate rules that implement not only the letter but the purposes of the Act. The deadline did not modify any express deadline in the law (there being none) and was germane to the policy of guaranteeing a full, free, and open party system with an informed electorate. The deadline was distinguished from the COMELEC Resolution invalidated in Lokin, which improperly added a new ground for substitution not found in the law.

• Grave Abuse of Discretion: The COMELEC committed grave abuse of discretion in approving the post-election substitution. Its clear disregard of its own deadline, the excessive speed at which the substitution was approved (one day from filing), the pre-approval of the new list pending compliance with the publication requirement, and the selective liberality shown toward a former commissioner—all taken together—demonstrated a pattern of whimsicality and arbitrariness. Commissioner Ferolino's memorandum detailed these irregularities. The approval was void and could not be the source of any right or obligation. However, P3PWD retained recourse under Section 16 to submit additional nominees upon exhaustion of the list during the term, but it was strictly enjoined from renominating the same five individuals for the duration of the Nineteenth Congress.

• Sub Judice Contempt: Guanzon was not held in contempt. Although her comments on jurisdiction approached contumacious conduct—seeming to prime public sentiment and invoking her legal expertise—several factors negated contumacious intent beyond reasonable doubt: she had not yet received a copy of the Petition when interviewed; her use of the phrase "without meaning to jump the gun on the Supreme Court" showed ostensible deference; and there was no clear and present danger to the Court's independence. In borderline instances, freedom of public comment weighs heavily against punishment.

• TRO Violation Contempt: The contempt charge in G.R. No. 261876 was dismissed. The TRO was addressed only to the COMELEC and the HOR, not to Guanzon personally. A party cannot be held in contempt for disobeying a court order not addressed to them. Her social media posts on June 29, 2022 did not prove knowledge of the TRO's existence or contents. However, her subsequent use of "Cong" or "Congresswoman" after notice of the TRO, while not contemptuous, contravened Canon II of the CPRA against disseminating false claims.

• Mandatory Nature of Substitution Deadlines After Elections — Rules and regulations governing the substitution of party-list nominees do not lose their mandatory character after elections because the timing of substitution is a matter of substance, not mere form. It affects the electorate's constitutional right to information on matters of public concern, enabling voters to make intelligent and informed choices. The qualified doctrine in Engle v. COMELEC—that election rules are directory after elections—applies only to matters of form, not substantial qualifications or requirements. Allowing blanket post-election substitution would negate the exceptional character of substitution and reduce elections to a "mere sport where players may be substituted at will or on a whim."

• Distinction Between Section 8 and Section 16 of R.A. No. 7941 — Section 8 of the Party-List System Act governs changes in the list of nominees before the term of the party-list representative begins (i.e., prior to noon of June 30 following the election). Section 16 applies only to vacancies in a party-list seat that legally exists, occurring during the term of the representative. Section 16 was crafted to provide a contingency for a future unexpected vacancy during the term, not to give party-list groups carte blanche to overhaul their list of nominees post-election but before the term commences.

• Administrative vs. Quasi-Judicial Functions of the COMELEC — The COMELEC's administrative function refers to the enforcement and administration of election laws. Its quasi-judicial function involves the resolution of controversies arising from the enforcement of election laws requiring determination of fact and adjudication of conflicting rights. The approval of substitution of nominees and the resolution of an opposition raising only questions of law (deadlines and jurisdiction) are administrative in nature. The existence of an opposition does not automatically convert a proceeding to quasi-judicial. A conflict between an alleged right and a general interest in law enforcement is not a conflict of rights requiring quasi-judicial adjudication.

• Voting Threshold for Administrative vs. Quasi-Judicial Matters — Article IX-A, Section 7 of the Constitution, requiring a majority vote of all members of the Commission, applies only to decisions, rulings, or orders rendered in the exercise of quasi-judicial powers. For administrative matters, Section 2 of COMELEC Resolution No. 9936 governs, requiring only a majority of all commissioners present at a meeting with a quorum.

• Grave Abuse of Discretion in COMELEC Actions — The COMELEC commits grave abuse of discretion when it violates its own mandatory rules on deadlines (citing Liberal Party v. COMELEC), acts with undue haste considered alongside other circumstances indicating arbitrariness, selectively applies its rules involving a former commissioner, and pre-approves actions subject to conditions precedent. A ruling tainted with grave abuse of discretion is void and cannot be the source of any right or obligation.

• Standing Based on Right to Information — In a petition anchored upon the right of the people to information on matters of public concern, which is a public right by its very nature, petitioners need not show any legal or special interest; it is sufficient to show they are citizens and part of the general public possessing the right (citing Akbayan Citizens Action v. Aquino).

• Interpretation of TRO Fallo and Body — Where there is no conflict between the body and the fallo of a TRO, the fallo should not be taken in isolation but must be read in connection with the other portions of the order. The absence of a directive in the dispositive portion does not constitute conflict if the intent is clear from the entire resolution.

• Sub Judice Contempt and the Clear and Present Danger Test — The "clear and present danger" rule governs contempt for utterances: the evil consequence must be "extremely serious and the degree of imminence extremely high" before speech can be punished. Factors negating contumacious intent include lack of knowledge of the petition's contents and expressions of deference to the court's authority. In borderline instances, freedom of public comment weighs heavily against a possible tendency to influence pending cases.

• "Nominee substitution being a matter of substance, rules and regulations governing the same do not lose their mandatory character even after the elections. A contrary rule would lead to the absurd result where a party need only wait for the elections to end before filing for substitution of nominees so that the COMELEC's deadline would not apply to it."

• "If We were to deem rules and regulations on nominee substitution as directory after elections, We would be negating the exceptional character of substitution. In effect, substitution would become the rule rather than the exception and parties would hardly be incentivized to field nominees with bona fide intention to assume office, thus reducing elections to a mere sport where players may be substituted at will or on a whim."

• "Although the people vote for the party-list organization itself in a party-list system of election, not for the individual nominees, they still have the right to know who the nominees of any particular party-list organization are. The publication of the list of the party-list nominees in newspapers of general circulation serves that right of the people, enabling the voters to make intelligent and informed choices. In contrast, allowing the party-list organization to change its nominees through withdrawal of their nominations, or to alter the order of the nominations after the submission of the list of nominees circumvents the voters' demand for transparency." (Quoting Lokin v. COMELEC)

• "The publication of the list of nominees does not only serve as the reckoning period of certain remedies and procedures under the resolution. Most importantly, the required publication satisfies the people's constitutional right to information on matters of public concern. The need for submission of the complete list required by law becomes all the more important in a party-list election to apprise the electorate of the individuals behind the party they are voting for. If only to give meaning to the right of the people to elect their representatives on the basis of an informed judgment, then the party-list group must submit a complete list of five nominees because the identity of these five nominees carries critical bearing on the electorate's choice. A post-election completion of the list of nominees defeats this constitutional purpose." (Quoting COCOFED v. COMELEC)

• "We cannot simply brush aside our Rules simply because the first nominee here is a former Commissioner. Making our Rules inapplicable to particular individuals or groups would suggest a double standard bordering on a lack of sense of fairness and justice." (Commissioner Ferolino's Memorandum)

• "Public office is a public trust, and public officers and employees must at all times be accountable to the people and serve them with utmost responsibility, integrity, loyalty and efficiency."

• "The least one can do when the time comes, out of respect for the electorate and the nation, is to accept the duty bestowed by the people without mental reservation or purpose of evasion."

• "Courts, after all, are courts of law and not of public opinion. Cases are decided on the merits and not through publicity. Those who seek judicial relief should be the first to respect and uphold the authority of the courts as impartial administrators of justice."

• Lokin v. COMELEC, 635 Phil. 372 (2010) — The Court ruled that Section 8 of R.A. No. 7941 enumerates three exclusive grounds for substitution (death, withdrawal in writing, incapacity). The COMELEC cannot add another ground. The publication of nominees' names serves the people's right to know and enables intelligent voting. Followed and applied to support that timing of substitution is substantive.

• COCOFED v. COMELEC, 716 Phil. 19 (2013) — The Court canceled a party-list's registration for failure to submit five nominees before elections, holding that the identity of nominees carries critical bearing on the electorate's choice. A post-election completion defeats the constitutional purpose of informed judgment. Followed and applied.

• Engle v. COMELEC, 778 Phil. 568 (2016) — The doctrine that election rules are directory after elections was qualified to refer only to matters of form and cannot apply to substantial qualifications of candidates. The Court warned against blanket application that may negate the electorate's right to information. Clarified and distinguished; the qualified doctrine was applied to hold that substitution deadlines are matters of substance.

• Mitra v. COMELEC, 648 Phil. 165 (2010) — The Court cautioned against blanket and unqualified reading of the directory-after-elections rule, holding that in a choice between material qualifications and the electorate's will, the former cannot be subordinated. Followed and applied.

• Bantay Republic Act (BA-RA 7941) v. COMELEC, 551 Phil. 1 (2007) — A writ of mandamus lies to compel disclosure of party-list nominees' names; the people have the right to elect representatives based on informed judgment. Followed and applied.

• Aggabao v. COMELEC, G.R. No. 258456, July 26, 2022 — Where supervening events create a legal controversy requiring determination of fact, the COMELEC must refer the matter to a Division and exercise quasi-judicial functions. Distinguished; here no legal controversy existed because no conflict of rights required adjudication.

• Akbayan Citizens Action v. Aquino, 580 Phil. 422 (2008) — In a petition anchored on the right to information on matters of public concern, petitioners need not show special interest; being citizens is sufficient. Applied to accord standing.

• Liberal Party v. COMELEC, 634 Phil. 468 (2010) — The COMELEC's violation of its own mandatory rules on deadlines constituted grave abuse of discretion. Applied.

• Garces v. Court of Appeals, 328 Phil. 403 (1996) — Article IX-A, Section 7 applies only to decisions, rulings, or orders in the exercise of quasi-judicial powers. Applied.

• Querubin v. COMELEC, 774 Phil. 766 (2015) — Reiterated that Article IX-A, Section 7's coverage is limited to adjudicatory or quasi-judicial powers. Applied.

• Jaramilla v. COMELEC, 460 Phil. 507 (2003) — A clerical correction in tabulation of results demands only administrative powers; the existence of an opposition does not automatically convert proceedings to quasi-judicial. Applied.

• Canicosa v. COMELEC, 347 Phil. 189 (1997) — The COMELEC need only apply the law and need not determine factual allegations where grounds invoked do not justify the relief sought; this is an exercise of administrative functions. Applied.

• Angcos v. Duterte Youth, G.R. No. 253805, November 3, 2020 (Unsigned Resolution) — A minute resolution involving different parties and subject matter does not constitute res judicata or binding precedent. Distinguished.

• ABS-CBN v. Ampatuan, G.R. No. 227004, April 25, 2023 — Enumerated the four ultimate facts required for a petition for indirect contempt and emphasized the clear and present danger test. Applied.

• Marantan v. Diokno, 726 Phil. 642 (2014) — The "clear and present danger" rule applies to contempt for utterances; the evil consequence must be extremely serious and the degree of imminence extremely high. Applied.

• Dumayas, Jr. v. COMELEC, 409 Phil. 407 (2001) — The basis for the majority vote under Article IX-A, Section 7 should be the incumbent members when the case was decided, not the total seats. Cited by dissent; not reached by majority since matter was deemed administrative.

• Republic v. De Los Angeles, 148-B Phil. 902 (1971) — A judgment must be read in its entirety; the fallo should not be taken in isolation. Applied to interpret the TRO.

• Section 8, Republic Act No. 7941 (Party-List System Act) — Provides that no change of names or alteration of the order of nominees shall be allowed after submission to the COMELEC except in cases of death, written withdrawal, or incapacity. The substitute nominee shall be placed last in the list. Applied as the governing provision for the substitution in this case, occurring prior to June 30, 2022.

• Section 16, Republic Act No. 7941 — In case of vacancy in a party-list seat, the vacancy shall be automatically filled by the next nominee in the order submitted. If the list is exhausted, the party shall submit additional nominees. Held applicable only to vacancies during the term of the representative, not to the post-election substitution here.

• Article IX-A, Section 7, 1987 Constitution — Each Commission shall decide by a majority vote of all its Members any case or matter brought before it. Held inapplicable because the assailed Resolutions were administrative, not quasi-judicial.

• Article IX-C, Section 3, 1987 Constitution — All election cases shall be heard and decided in division; motions for reconsideration shall be decided by the COMELEC En Banc. Held inapplicable because no quasi-judicial election case was involved.

• Section 2, COMELEC Resolution No. 9936 — A decision on an administrative matter shall be valid when approved by a majority of all members present at a meeting with a quorum. Applied as the governing voting threshold; the three-to-one vote was valid.

• Sections 4 and 5, Rule 4, COMELEC Resolution No. 9366, as amended by Resolution No. 10690 — Set November 15, 2021 as the deadline for withdrawal and substitution of party-list nominees, and mid-day of election day for substitutions due to death or incapacity. These deadlines were held mandatory even after elections.

• Rule 71, Section 3(d), Rules of Court — Indirect contempt for disobedience or resistance to a lawful writ, process, order, or judgment of a court. Applied to the contempt charges; both were dismissed.

• Canon II, Code of Professional Responsibility and Accountability (CPRA) — Lawyers shall act with propriety, uphold the dignity of the legal profession; Section 19 prohibits commenting on pending proceedings to sway public perception. Section 38 prohibits knowingly disseminating false claims on social media. Guanzon was reminded of her obligations under this Canon.

Chief Justice Gesmundo, Justices Caguioa, Hernando, Zalameda, M. Lopez, Gaerlan, Dimaampao, Marquez, and Singh concurred. Senior Associate Justice Leonen filed a separate concurring and dissenting opinion.

• Senior Associate Justice Leonen (Concurring and Dissenting) — Concurred that the Petition should be granted but dissented as to the directive for P3PWD to submit additional nominees. He would have directed P3PWD to choose its nominee from the second list (Yeneza et al.) because the withdrawals should never have been granted. He emphasized that the party-list system was designed to foster representation of ideologies and causes, not personalities; the COMELEC's cavalier attitude toward wholesale post-election substitution abuses the system. He noted the clear conflict of interest in Guanzon's involvement—she was a sitting commissioner when P3PWD's registration was approved and became a member two days after retirement. He further noted that prevailing COMELEC rules for the 2022 elections (Resolution No. 10690) did not allow exhaustion of the list due to withdrawal of acceptance of nomination, only death or incapacity. Guanzon herself had previously argued against post-deadline substitution when she was a commissioner.

• Justice Caguioa (Dissenting) — Voted to deny the petition. He argued that (1) the COMELEC has exclusive jurisdiction over withdrawal and substitution; (2) the Third Assailed Resolution was quasi-judicial and void for not having been first resolved by a Division; (3) it was ultra vires for COMELEC to set substitution deadlines because Section 8 of R.A. No. 7941 sets no such deadline, unlike Section 77 of the Omnibus Election Code, and the legislative intent was to allow substitution at any time to ensure party-lists always have nominees; (4) the publication requirement serves to allow scrutiny of nominees' qualifications, not to facilitate informed voting, since voters vote for party-lists, not nominees; (5) there was no legal basis to find grave abuse of discretion because the COMELEC's speed was within legally sanctioned periods, no evidence showed Guanzon's status influenced the decision, and Duterte Youth itself had previously been allowed similar relief; and (6) barring renomination effectively disqualifies individuals without any lawful ground for disqualification.

• Justice J. Lopez (Dissenting) — Voted to declare the assailed Minute Resolutions valid. He argued that the three-to-one vote was valid even if the matter were quasi-judicial because the "majority of all its Members" should be based on incumbent commissioners, not filled seats, following Dumayas, Jr. v. COMELEC. He further argued that Section 16 of R.A. No. 7941 covers vacancies occurring immediately after elections, not only from noon of June 30, and the law does not distinguish as to the timing or cause of vacancy. Enjoining the renomination of the five substitutes punishes them for COMELEC's perceived error without due process and violates P3PWD's right to free association in choosing its representatives.