Liberal Party vs. Commission on Elections

The deadline for registration of political parties under COMELEC Resolution No. 8646 is mandatory and jurisdictional, and applies generically to political parties, organizations, and coalitions alike. The COMELEC's grant of registration to a coalition beyond its own set deadline constitutes grave abuse of discretion amounting to lack or excess of jurisdiction, rendering the registration void. Political coalitions must register in accordance with established norms and procedures to be recognized as such and to receive the benefits accorded by law to registered coalitions; the freedom to coalesce is distinct from the formal recognition the Constitution requires for a political party, organization, or coalition to be entitled to full and meaningful participation in elections.

The Liberal Party (LP), represented by its President Manuel A. Roxas II and Secretary General Joseph Emilio A. Abaya, filed a petition for certiorari and prohibition assailing the COMELEC en banc's Per Curiam Resolution dated April 12, 2010 in SPP-10-(DM). The challenged Resolution granted the application for registration of the Nacionalista Party–Nationalist People's Coalition (NP-NPC) as a political coalition and deferred the question of the coalition's dominant minority status to a future resolution. The case arose in the context of the May 10, 2010 elections, the first time the country would use an automated election system, and involved the registration of political coalitions, the grant of accreditation to dominant parties, and the validity of the COMELEC en banc's authority to act on the registration of political coalitions.

The Liberal Party (LP), represented by its President Manuel A. Roxas II and Secretary General Joseph Emilio A. Abaya, and the Nacionalista Party (NP) and Nationalist People's Coalition (NPC) were political parties participating in the May 10, 2010 elections, the first automated elections in the country. On July 14, 2009, the COMELEC promulgated Resolution No. 8646, which set August 17, 2009 as the last day for the filing of petitions for registration of political parties. On January 21, 2010, the COMELEC promulgated Resolution No. 8752, which provided rules for the filing of petitions for accreditation for the determination of the dominant majority party, the dominant minority party, ten major national parties, and two major local parties, and set the deadline for filing accreditation petitions on February 12, 2010.

On February 12, 2010, the LP filed with the COMELEC its petition for accreditation as dominant minority party. On the same date, the NP and the NPC filed a petition for registration as a coalition (NP-NPC) and asked that it be recognized and accredited as the dominant minority party for purposes of the May 10, 2010 elections. The petition was docketed as an SPP (DM) case, indicating that it was an accreditation case. On February 23, 2010, the LP filed its Opposition to the NP-NPC's petition on the following grounds: (1) the NP-NPC's petition should be denied since it was not a duly registered coalition at the time of filing; (2) the COMELEC en banc had no jurisdiction to entertain the petition for registration as a coalition because it should have been first brought before the proper Division; (3) the petition was filed with the Clerk of the Commission instead of the Law Department in violation of the COMELEC Rules of Procedure; (4) the petition was filed beyond the August 17, 2009 deadline; and (5) the respective chapters, incumbents, and candidates of the NP and NPC separately could not be taken into account for accreditation purposes because the NP-NPC as a coalition was an entirely different entity.

The COMELEC issued an Order dated February 16, 2010 and a Notice of Hearing on February 17, 2010 setting for hearing the petitions for accreditation. On March 9, 2010, the LP presented Rep. Lualhati Antonino, a member of the NPC's National Convention, as its witness. Rep. Antonino testified that the NPC National Convention did not authorize its National Central Committee to enter into a coalition with the NP, and that neither the National Convention nor the general membership was ever consulted about the merger with the NP. On March 10, 2010, the NP-NPC presented former Gov. Faustino Dy, Jr. as its witness to refute Rep. Antonino's testimony. On March 15, 2010, the LP and the NP-NPC filed their respective Memoranda.

On April 12, 2010, the COMELEC en banc granted the NP-NPC's petition for registration as a coalition through the assailed Resolution, and deferred the resolution of the NP-NPC's application for accreditation as dominant minority party. The en banc held that the registration of coalitions involves the exercise of its administrative powers and not its quasi-judicial powers, citing Baytan vs. COMELEC, and that the en banc can act directly on matters falling within its administrative powers. The en banc ruled that although the NP-NPC's failure to file the petition with the Law Department constituted a violation of the COMELEC Rules of Procedure, the en banc had discretion to suspend the application of the rules in the interest of justice. On timeliness, the en banc held that no rule exists setting a deadline for the registration of coalitions, and that registration of a coalition is simply a recognition by the COMELEC of a political reality — an "operative fact." On the merits, the en banc found that both the NP and NPC validly agreed to join forces, that the NP-NPC satisfactorily submitted all documentary requirements, and that the LP, as a stranger to the internal dynamics of both parties, lacked standing to question the coalition. The en banc disregarded Rep. Antonino's testimony on the ground that she lost her NPC membership when she admitted support for the candidacy of Sen. Manuel A. Roxas II, a ground provided under the NPC's Constitution and By-Laws.

Commissioner Rene V. Sarmiento dissented on various grounds: (1) the COMELEC sitting en banc had no jurisdiction over the petition, as Rule 32 of the COMELEC Rules governs the registration of coalitions and is found under "Special Proceedings," which under Section 3 of the COMELEC Rules falls within the jurisdiction of the Commission sitting in Divisions; (2) the relaxation of the rules was inappropriate because the petition falls under provisions that candidates are required to comply with, which are necessarily mandatory; (3) no valid coalition was formed because the Constitutions and By-Laws of both parties require approval of their respective National Conventions, and the action of the Executive Committees in issuing the Joint Resolution was ultra vires and void; (4) the NP-NPC was a sham whose sole purpose was to secure dominant minority party status; and (5) the NP-NPC could not seek accreditation without the requisite recognition by the COMELEC, and the deadline for filing a petition for accreditation had lapsed.

The LP assailed the April 12, 2010 COMELEC Resolution for having been issued with grave abuse of discretion on the following grounds: (1) the COMELEC en banc had no jurisdiction at the first instance to entertain petitions for registration of political coalitions; (2) the COMELEC gravely abused its discretion when it allowed the registration of the NP-NPC despite the lapse of the deadline for registration; (3) the COMELEC gravely abused its discretion when it allowed the registration despite patent and manifest violations of the NPC Constitution and By-Laws; and (4) the NP-NPC coalition was a bogus, sham, and paper coalition. The LP attached the Sworn Affidavits of Atty. Sixto S. Brillantes, the NPC Legal Counsel, and Daniel Laogan, a member of the NPC's National Central Committee, to show that the NP-NPC was entered into without consultations and without the approval of the NPC's National Convention.

The Office of the Solicitor General (OSG) argued that the petition was premature, as the assailed Resolution only affirmatively resolved the registration of the NP-NPC, not its accreditation, and that no violation of due process attended the registration process. The NP-NPC argued that the petition should be dismissed for procedural infirmities, including failure to attach certified true copies of material portions of the record, failure to implead the NP-NPC as an indispensable party, and that the petition raised mere errors of judgment not correctible by certiorari. On the merits, the NP-NPC argued that the en banc had jurisdiction as registration falls within the COMELEC's administrative powers, that the petition for registration was not time-barred because the August 17, 2009 deadline applied only to political parties and not to coalitions, that the NP-NPC was validly formed with requisite approvals duly obtained, and that the affidavits attached to the petition were inadmissible hearsay.

• Jurisdiction of the En Banc: Petitioner argued that the COMELEC en banc had no jurisdiction at the first instance to entertain petitions for registration of political coalitions, as Rule 32 of the COMELEC Rules of Procedure provides that registration is under the jurisdiction of a Division at the first instance.
• Timeliness of Registration: Petitioner argued that the COMELEC gravely abused its discretion when it allowed the registration of the NP-NPC coalition despite the lapse of the August 17, 2009 deadline for registration set by COMELEC Resolution No. 8646.
• Violation of NPC Constitution and By-Laws: Petitioner argued that the COMELEC gravely abused its discretion when it allowed the registration of the NP-NPC coalition despite patent and manifest violations of the NPC Constitution and By-Laws, as the NPC National Convention did not authorize the coalition.
• Sham Coalition: Petitioner argued that the NP-NPC coalition was a bogus, sham, and paper coalition that made a mockery of the electoral process, as members of the NP and NPC were pitted against each other for the same election positions.

• Procedural Infirmities: Respondents argued that the petition should be dismissed outright because the petitioner violated Section 5(2) of Rule 64 of the Rules of Court by failing to attach certified true copies of material portions of the record, and unjustifiably failed to implead the NP-NPC as a real party-in-interest and indispensable party.
• Errors of Judgment: Respondents argued that the petition raised mere errors of judgment not within the Court's authority to act upon under its certiorari jurisdiction, since it merely assailed the en banc's appreciation of facts and evidence.
• Jurisdiction of the En Banc: Respondents argued that the en banc had jurisdiction to entertain the petition for registration, as registration falls within the ambit of the COMELEC's administrative powers under Section 2(5) of Article IX of the Constitution, citing Baytan vs. COMELEC.
• Timeliness of Registration: Respondents argued that the petition for registration as a coalition was not time-barred, as the August 17, 2009 deadline applied only to "political parties" and to "parties, organizations and coalitions under the party-list system," and no deadline was set for petitions for registration of coalitions between previously registered political parties.
• Validity of the Coalition: Respondents argued that the NP-NPC was validly formed and that the requisite approvals were duly obtained, that the 1993 Revised Rules of the NP do not require the approval of the National Convention for coalescing, that the NPC's Constitution and By-Laws is silent on the power to approve a coalition, and that no member of either party has objected to the coalition.
• Admissibility of Evidence: Respondents argued that the newspaper reports and affidavits of Atty. Brillantes and Daniel Laogan attached to the petition were inadmissible hearsay, as the Court cannot receive evidence or conduct a trial de novo under its certiorari jurisdiction, and Atty. Brillantes' affidavit was covered by attorney-client privilege.

• Procedural and Technical Infirmities: Whether the petition should be dismissed outright for procedural and technical infirmities, including failure to attach certified true copies of documents and failure to implead the NP-NPC as an indispensable party.
• Prematurity: Whether the present petition is premature since its object is to foreclose a ruling on the unsettled NP-NPC accreditation issue.
• Timeliness of Registration: Whether the NP-NPC petition before the COMELEC, viewed as a petition for registration, is time-barred.
• "Operative Fact" Doctrine: Whether the NP-NPC is an "operative fact" that the COMELEC simply has to note and recognize without need of registration.
• Jurisdiction of the En Banc: Whether the COMELEC en banc has jurisdiction at the first instance to entertain the petition for registration of a political coalition.
• Grave Abuse of Discretion: Whether, assuming the en banc has jurisdiction, it gravely abused its discretion when it allowed the registration of the NP-NPC, particularly regarding due process and compliance with the internal rules of the NP and NPC.

• Procedural and Technical Infirmities: No. The Court viewed the technical and procedural threshold issues with liberality given the grave public interests involved, noting that the respondents did not deny the existence and basic correctness of the attachments, and that the NP-NPC did not legally exist as a coalition with a personality separate from its component parties without any finally confirmed registration.
• Prematurity: No. The petition was not premature. The registration of a coalition and the accreditation of a dominant minority party are separate matters, but they are linked and sequentially follow one another; accreditation can only be granted to a registered political party, organization, or coalition. After the en banc issued the assailed Resolution resolving the registration application, the COMELEC's part in the registration process was brought to a close, rendering the Resolution ripe for review.
• Timeliness of Registration: Yes. The NP-NPC's petition for registration as a coalition was time-barred. The August 17, 2009 deadline under Resolution No. 8646 applies generically to political parties, organizations, and coalitions, and the en banc acted in excess of its jurisdiction when it granted the registration beyond the deadline.
• "Operative Fact" Doctrine: No. The "operative fact" doctrine was rejected. The freedom to coalesce is different from the formal recognition the Constitution requires for a political party, organization, or coalition to be entitled to full and meaningful participation in elections. Political coalitions need to register in accordance with established norms and procedures to be recognized and receive the benefits accorded by law.
• Jurisdiction of the En Banc: Not reached. The Court reserved for another case the answer to the question of whether the en banc has jurisdiction at the first instance to entertain petitions for registration of political coalitions, given the decisive impact of the ruling on timeliness.
• Grave Abuse of Discretion: Yes. The en banc gravely abused its discretion when it disregarded its own mandatory deadline in ruling on the registration of the NP-NPC as a coalition, which was a grave abuse of discretion that fatally afflicted the assailed COMELEC Resolution.

• Procedural and Technical Infirmities: The Court noted that a primary factor in considering technical and procedural objections is the nature of the issues involved. The Court has been strict when issues are solely confined to the parties' private interests, but has viewed with liberality the technical and procedural threshold issues raised when grave public interests are involved. The registration of political parties, their accreditation as dominant parties, and the benefits these recognitions provide constitute distinct advantages to any party and its candidates, particularly in an automated election system. The Court found that the respondents' objection to defects in the attachments was a formal one, as they did not deny the existence and basic correctness of these attachments. The Court also found that the failure to formally implead the NP-NPC was not a sufficient reason to dismiss, as without any finally confirmed registration, the NP-NPC did not legally exist as a coalition with a personality separate and distinct from the component NP and NPC parties. The Court further held that the petition passed the facial objection test, as the alleged unwarranted action of the en banc in acting on the registration when the COMELEC's own Rules of Procedure provides that registration is under the jurisdiction of a Division at the first instance, and the approval of registration beyond the cut-off date, were allegations of ultra vires acts constituting grave abuse of discretion, not mere errors of law.
• Prematurity: The Court ruled that the OSG's objection based on prematurity was groundless. The registration of a coalition and the accreditation of a dominant minority party are two separate matters that are substantively distinct from each other. Registration is the act that bestows juridical personality for purposes of election laws; accreditation relates to the privileged participation that election laws grant to qualified registered parties. However, accreditation can only be granted to a registered political party, organization, or coalition; a registration must first take place before a request for accreditation can be made. Once registration has been carried out, accreditation is the next natural step to follow. Under Rule 13, Section 1(d) of the COMELEC Rules, a motion for reconsideration of an en banc ruling is a prohibited pleading, except in election offense cases. Thus, after the en banc issued the assailed Resolution resolving the registration application, the COMELEC's part in the registration process was brought to a close, rendering the Resolution ripe for review. From the point of view of prohibition, there was no prematurity as its avowed intent was to forestall an event — the accreditation — that according to the assailed Resolution shall soon take place.
• Timeliness of Registration: The Court held that the NP-NPC's petition for registration as a coalition was time-barred. While Resolution No. 8646 states that August 17, 2009 is the "[L]ast day for filing petitions for registration of political parties," without mentioning "organizations and coalitions," the Resolution is simply a listing of electoral activities and deadlines for the May 10, 2010 elections, not a resolution aimed at establishing distinctions among "political parties, organizations, and coalitions." 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. The Court noted that no substantial distinction exists among these entities germane to the act of registration that would justify creating distinctions among them in terms of deadlines. The Court found that the deadline for registration cannot but be a firm and mandatory deadline, given the close step-by-step procedure the COMELEC has to undertake in implementing the automated election system, including the holding of political conventions, the filing of certificates of candidacy, the examination and testing of equipment, the nomination of official watchers, and the printing, storage, and distribution of official ballots. The Court noted that the COMELEC has in the past rejected applications for registration for having been filed out of time, citing the application of Philippine Guardians Brotherhood, Inc. The Court held that the mandatory deadline is effectively a jurisdictional matter that should have been satisfied and was not; where conditions that authorize the exercise of a general power are wanting, fatal excess of jurisdiction results. The Court found the en banc's position that the deadline for registration is only for "political parties" and not for "organizations and coalitions" to be preposterous and patently unreasonable, made without basis in law, in fact, or in reason, constituting grave abuse of discretion that fatally afflicted the assailed COMELEC Resolution.
• "Operative Fact" Doctrine: The Court categorically rejected the COMELEC's position that the coalition was an "operative fact" that the en banc could note and thereafter recognize, implying that coalitions of political parties may not need any separate registration if the component parties are already registered. The Court held that the freedom to coalesce or to work together in an election to secure the vote for chosen candidates is different from the formal recognition the Constitution requires for a political party, organization, or coalition to be entitled to full and meaningful participation in the elections and to the benefits that proceed from formal recognition. Registration and the formal recognition that accompanies it are required because of the Constitution's concern about the character of the organizations officially participating in the elections, including religious and ideological limitations and the bar on alien participation and influence. Registration must be undertaken under the strict formalities of the law, including the time limits and deadlines set by the proper authorities. The Court concluded that political coalitions need to register in accordance with the established norms and procedures, if they are to be recognized as such and be given the benefits accorded by law to registered coalitions. Registered political parties carry a different legal personality from that of the coalition they may wish to establish with other similarly registered parties.
• Jurisdiction of the En Banc: The Court reserved for another case and another time the answers to the questions of whether the en banc has jurisdiction at the first instance to entertain petitions for registration of political coalitions, given the time constraints and the decisive impact of the ruling on timeliness. The Court solely ruled for now that the en banc gravely abused its discretion when it disregarded its own deadline in ruling on the registration of the NP-NPC as a coalition.
• Grave Abuse of Discretion: The Court held that the en banc gravely abused its discretion when it disregarded its own deadline in ruling on the registration of the NP-NPC as a coalition. The Court emphasized that the matter of party registration raises critical election concerns that should be handled with discretion commensurate with the importance of elections to the democratic system, and that the COMELEC should be at its most strict in implementing and complying with the standards and procedures the Constitution and laws impose.

• Mandatory Nature of COMELEC Deadlines — The deadline for registration of political parties set by the COMELEC is firm and mandatory, not merely directory. The Court applied this doctrine by holding that the August 17, 2009 deadline under Resolution No. 8646 was a jurisdictional matter, and the COMELEC's grant of registration to the NP-NPC beyond this deadline constituted fatal excess of jurisdiction.
• Generic Meaning of "Political Parties" — The term "political parties" in a COMELEC deadline-setting resolution should be understood in its generic sense that covers political organizations and political coalitions as well, absent any note, explanation, or reason why the deadline only mentions political parties. The Court applied this doctrine to hold that the August 17, 2009 deadline applied to the NP-NPC's petition for registration as a coalition.
• Registration vs. Accreditation — Registration is the act that bestows juridical personality for purposes of election laws; accreditation relates to the privileged participation that election laws grant to qualified registered parties. The Court applied this doctrine to hold that accreditation can only be granted to a registered political party, organization, or coalition, and that a registration must first take place before a request for accreditation can be made.
• "Operative Fact" Doctrine Rejected — The freedom to coalesce or to work together in an election is different from the formal recognition the Constitution requires for a political party, organization, or coalition to be entitled to full and meaningful participation in elections. The Court applied this doctrine to reject the COMELEC's position that the NP-NPC coalition was an "operative fact" that the COMELEC could simply note and recognize without need of registration.
• Grave Abuse of Discretion — Grave abuse of discretion implies such capricious and whimsical exercise of judgment as to be equivalent to lack or excess of jurisdiction; power is exercised in an arbitrary or despotic manner by reason of passion, prejudice, or personal hostility, and such exercise is so patent or so gross as to amount to an evasion of a positive duty or to a virtual refusal either to perform the duty enjoined or to act at all in contemplation of law. The Court applied this doctrine in finding that the COMELEC's disregard of its own mandatory deadline was patently unreasonable, made without basis in law, in fact, or in reason.

• "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." — This passage articulates the Court's interpretation of COMELEC Resolution No. 8646, holding that the August 17, 2009 deadline applied generically to political parties, organizations, and coalitions, and is central to the Court's finding that the NP-NPC's registration was time-barred.
• "Effectively, the mandatory deadline is a jurisdictional matter that should have been satisfied and was not. Where conditions that authorize the exercise of a general power are wanting, fatal excess of jurisdiction results." — This passage states the Court's holding that the COMELEC's mandatory deadline for registration is jurisdictional in nature, and that acting beyond it constitutes fatal excess of jurisdiction.
• "The freedom to coalesce or to work together in an election to secure the vote for chosen candidates is different from the formal recognition the Constitution requires for a political party, organization or coalition to be entitled to full and meaningful participation in the elections and to the benefits that proceed from formal recognition." — This passage articulates the Court's rejection of the "operative fact" doctrine and clarifies the distinction between the freedom to coalesce and the constitutional requirement of formal registration.
• "In our view, this kind of ruling was patently unreasonable, made as it was without basis in law, in fact or in reason; and was a grave abuse of discretion that fatally afflicted the assailed COMELEC Resolution." — This passage states the Court's finding that the COMELEC en banc's ruling on the timeliness of the registration was a grave abuse of discretion amounting to lack or excess of jurisdiction.

• Baytan vs. COMELEC, G.R. No. 153945, February 4, 2003, 396 SCRA 703 — Cited by the COMELEC en banc and respondents as authority that the registration of political parties and coalitions falls within the COMELEC's administrative powers under Section 2(5) of Article IX of the Constitution, and that the en banc can act directly on matters falling within its administrative powers. The Court did not reach this issue in its ruling.
• Villarosa vs. COMELEC, G.R. No. 133927, November 29, 1999, 319 SCRA 470 — Cited by Commissioner Sarmiento in his dissent as authority that the petition for registration of a coalition is within the jurisdiction of the COMELEC sitting in Division, not the en banc. The Court did not reach this issue in its ruling.
• Madrigal Transport, Inc. vs. Lapanday Holdings Corporation, G.R. No. 156067, August 11, 2004, 436 SCRA 123 — Cited by the Court for its succinct exposition of grave abuse of discretion amounting to lack or excess of jurisdiction in relation to errors of law, distinguishing between errors of jurisdiction and errors of judgment.
• Sinaca vs. Mula, 373 Phil. 896 (1999) — Cited by respondents as authority that political parties are generally free to conduct their internal affairs free from judicial supervision. The Court did not reach this issue in its ruling.
• Philippine Guardians Brotherhood, Inc. vs. Commission on Elections, G.R. No. 190529, May 1, 2010 — Cited by the Court as a case where the COMELEC denied a plea for registration for having been filed out of time, demonstrating that the COMELEC has in the past rejected applications for registration filed beyond the deadline.
• Information Technology Foundation of the Philippines vs. Commission on Elections, G.R. No. 159939, January 13, 2004, 419 SCRA 141 — Cited by the Court as authority that the COMELEC gravely abused its discretion in arbitrarily failing to observe its own rules, policies, and guidelines.

• Section 2(5), Article IX-C, 1987 Constitution — Provides that the COMELEC shall "[r]egister, after sufficient publication, political parties, organizations, or coalitions which, in addition to other requirements, must present their platform or program of government." The Court applied this provision in holding that registration and formal recognition are required for a political party, organization, or coalition to be entitled to full and meaningful participation in elections.
• Section 1, Rule 32, COMELEC Rules of Procedure — Provides that any political party, organization, or coalition of political parties seeking registration shall file with the Law Department of the Commission a petition duly verified by its President and Secretary-General. The Court noted this provision in discussing the registration process.
• Section 3, Rule 3, COMELEC Rules of Procedure — Provides that the Commission shall sit in two Divisions to hear and decide protests or petitions in ordinary actions, special actions, special cases, provisional remedies, contempt, and special proceedings, except in accreditation of citizens' arms of the Commission. The Court noted this provision in discussing the jurisdictional question.
• Section 4, Rule 1, COMELEC Rules of Procedure — Provides for the COMELEC's discretion to suspend the application of its rules in the interest of justice and speedy disposition of cases. The Court implicitly rejected the COMELEC's reliance on this provision in finding that the deadline for registration was mandatory.
• Section 1(d), Rule 13, COMELEC Rules of Procedure — Provides that a motion for reconsideration of an en banc ruling is a prohibited pleading, except in election offense cases. The Court applied this provision in holding that the assailed Resolution was ripe for review.
• Section 5(2), Rule 64, Rules of Court — Requires that a petition be accompanied by certified true copies of such material portions of the record referred to in the petition. The Court considered the respondents' objection based on this provision but overruled it given the weight of counterbalancing factors.
• Section 1, Article VIII, 1987 Constitution — Provides that judicial power includes the power to determine whether or not there has been a grave abuse of discretion amounting to lack or excess of jurisdiction on the part of any branch or instrumentality of the Government. Cited in the concurring opinion of Justice Carpio.

Puno, C.J., Carpio, Corona, Carpio Morales, Velasco, Jr., Nachura, Leonardo-De Castro, Peralta, Bersamin, Del Castillo, Abad, Villarama, Jr., Perez, and Mendoza, JJ., concurred. Justice Carpio wrote a separate concurring opinion, additionally holding that the NP and NPC officers who signed the coalition agreement acted without authority in violation of their parties' respective Constitutions and By-Laws, and that the COMELEC committed grave abuse of discretion for violating its own rules as well as its constitutional mandate of insuring orderly and credible elections.

• Corona, J. — Dissented on the ground that the COMELEC committed no grave abuse of discretion in this case that would justify the grant of the extraordinary writ of certiorari. Justice Corona anchored his dissent on the position that the power of the COMELEC to register political parties, organizations, or coalitions is among the COMELEC's administrative powers that may be acted on directly by the COMELEC en banc, citing Baytan vs. COMELEC and Bautista vs. COMELEC. He argued that even assuming the COMELEC en banc was wrong when it acted directly on the petition, it committed a mere error of judgment, which is not correctible by the writ of certiorari.