Primary Holding

The Supreme Court ruled that Section 13 of COMELEC Resolution No. 7804 was invalid to the extent it allowed a party to unilaterally change or substitute its nominees after submission of the list to the COMELEC. The statutory grounds for substitution under R.A. No. 7941 are exclusive.

Background

CIBAC submitted its list of nominees for the 2007 elections, which included Lokin as the second nominee. Subsequently, CIBAC's president filed an amended list replacing Lokin and others with new nominees. COMELEC relied on Section 13 of Resolution No. 7804 to approve this substitution. Lokin challenged the substitution and sought to be proclaimed as CIBAC's second nominee.

Facts

• 1. CIBAC (Citizens' Battle Against Corruption), a registered party-list organization, submitted its list of nominees for the 2007 elections, as required under the Party-List System Act (R.A. No. 7941). The list included Luis K. Lokin, Jr. as the second nominee.
• 2. After the elections, CIBAC won two congressional seats, entitling its top two nominees to be seated in the House of Representatives.
• 3. Before the nominees could be proclaimed, CIBAC’s president, Velarde, submitted an amended list of nominees to the Commission on Elections (COMELEC). The amended list removed Lokin and substituted him with a new individual.
• 4. The amendment was based on Section 13 of COMELEC's Resolution No. 7804, which allowed political parties or organizations to substitute nominees.
• 5. Lokin contested this substitution, claiming it violated R.A. No. 7941, which allows substitutions only in three specific circumstances: death, withdrawal in writing, or incapacity of the nominee.
• 6. Lokin asserted that his removal was illegal and that COMELEC had no legal basis to accept an amended nominee list outside of the grounds provided in the law.
• 7. COMELEC approved the substitution, prompting Lokin to file petitions for certiorari, mandamus, and prohibition against the COMELEC and CIBAC.

Arguments of the Petitioners

• 1. Lokin argued that the substitution violated R.A. No. 7941, which does not allow unilateral withdrawal or substitution by the party after the list is submitted.
• 2. He claimed the changes lacked legal basis and undermined transparency in the party-list system.

Arguments of the Respondents

• 1. COMELEC asserted that Section 13 of its Resolution No. 7804 provided legal grounds for the substitution.
• 2. CIBAC argued that Lokin's petitions constituted forum shopping and that the decision to amend the list was within its internal discretion.

Issues

• 1. Does the Supreme Court have jurisdiction to review the case?
• 2. Did Lokin engage in forum shopping?
• 3. Is Section 13 of Resolution No. 7804 valid under the Party-List System Act?
• 4. Did COMELEC commit grave abuse of discretion in allowing the substitution?

Ruling

• 1. The Court has jurisdiction since the case concerns grave abuse of discretion by COMELEC.
• 2. Lokin was not guilty of forum shopping, as his petitions sought separate remedies.
• 3. Section 13 of Resolution No. 7804 was invalid for introducing a ground for substitution (withdrawal by the party) not provided in R.A. No. 7941.
• 4. COMELEC abused its discretion by approving the substitution based on an invalid rule.

Doctrines

• 1. Doctrine of Administrative Law: Administrative rules cannot amend or expand the provisions of a statute; they must conform precisely.
• 2. Statutory Construction: Clear statutory language must be interpreted literally, and exceptions explicitly stated are exclusive.

Precedents Cited

• 1. Executive Secretary v. Gordon (on forum shopping)
• 2. Metropolitan Bank and Trust Company v. NWPC (on validity of administrative rules)
• 3. Salaysay v. Castro (on statutory exceptions)

Statutory and Constitutional Provisions

• 1. Section 8, R.A. No. 7941 (Party-List System Act)
• 2. Section 13, COMELEC Resolution No. 7804 (invalid provision on substitution)
• 3. 1987 Constitution, Article IX-C, Section 2(1) (COMELEC powers)