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Sep 11, 2024 Case Briefs Download PDF

CASE DIGEST

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Grace B. Licudan
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18 views3 pages

Sep 11, 2024 Case Briefs Download PDF

CASE DIGEST

Uploaded by

Grace B. Licudan
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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G.R. No. 189466.

February 11, 2010 (Case Brief / Digest)

Sep 11, 2024

– Case Briefs

Download PDF

**Title:**
Abayon vs. House of Representatives Electoral Tribunal, G.R. Nos. 189466 & 189506

**Facts:**

1. **2007 Elections:**
– Daryl Grace J. Abayon was the first nominee for Aangat Tayo party-list.
– Jovito S. Palparan, Jr. was the first nominee for Bantay party-list.
– Both party-list groups won seats in the House of Representatives.

2. **Quo Warranto Petitions Against Abayon:**


– Registered voters Perfecto C. Lucaban, Jr., Ronyl S. Dela Cruz, and Agustin C. Doroga filed a quo
warranto petition against Aangat Tayo and Abayon in HRET Case 07-041.
– They claimed Aangat Tayo was ineligible for a party-list seat as it did not represent marginalized and
underrepresented sectors.
– They also argued Abayon was unqualified because she was the wife of a current congressman and had
previously lost a bid as a nominee for another party-list (An Waray) in 2004.

3. **Abayon’s Defense:**
– Abayon argued that COMELEC had already validated Aangat Tayo’s status.
– She stated she belonged to the women sector, and the HRET lacked jurisdiction over collateral attacks
on Aangat Tayo’s registration.
– Abayon maintained that the eligibility questions were an internal party concern.

4. **HRET Ruling on Abayon:**


– HRET dismissed the petition against Aangat Tayo but upheld its jurisdiction over Abayon’s
qualifications.
– Abayon’s motion for reconsideration was denied, leading her to file a certiorari petition with the
Supreme Court.

5. **Quo Warranto Petitions Against Palparan:**


– Lesaca and others filed a quo warranto petition against Bantay and Palparan in HRET Case 07-040.
– They asserted Palparan did not belong to the marginalized sectors represented by Bantay and was
responsible for human rights violations against such sectors.

6. **Palparan’s Defense:**
– Palparan contended that Bantay, not he, assumed membership in the House, making questions about
his eligibility an internal matter for Bantay.
– He maintained that the HRET lacked jurisdiction.

7. **HRET Ruling on Palparan:**


– HRET dismissed the petition against Bantay based on COMELEC’s jurisdiction but upheld its jurisdiction
over Palparan’s qualifications.
– Palparan’s motion for reconsideration was denied, prompting a certiorari petition to the Supreme
Court.

8. **Consolidation:**
– The Supreme Court consolidated the cases due to the common issue of HRET jurisdiction over party-list
nominees.

**Issues:**

1. **Does the HRET have jurisdiction to decide on the qualifications of party-list nominees already
seated in the House of Representatives?**
2. **Does the specific authority to judge the qualifications of party-list nominees lie exclusively with the
COMELEC based on their initial approval of party-list groups?**
3. **Is the determination of party-list nominees’ qualifications an internal matter for the nominating
party-list organization itself?**

**Court’s Decision:**

1. **Jurisdiction of HRET:**
– The Supreme Court held that the HRET has jurisdiction over the qualifications of party-list
representatives as they are Members of the House of Representatives. This power is derived from
Section 17, Article VI of the Constitution.

2. **Role of COMELEC:**
– Although COMELEC handles the registration and initial qualification of party-list organizations, once
elected and seated, the jurisdiction to assess qualifications of individual representatives shifts to the
HRET.

3. **Party-List Nominee Membership:**


– The Court emphasized that party-list nominees, once elected, are considered members of the House of
Representatives under the Constitution and the Party-List System Act.

4. **Proceedings Validated:**
– The Court found no grave abuse of discretion by the HRET in dismissing petitions against party-list
organizations but upholding jurisdiction over individual nominee qualifications.

**Doctrine:**

– **HRET Sole Judge Authority:** Section 17, Article VI of the Philippine Constitution vests the HRET
with exclusive jurisdiction to judge all contests relating to the election, returns, and qualifications of
House members, including party-list nominees.
– **Member-Representative Equivalence:** Party-list nominees, once seated, are equivalent to district
representatives under constitutional and statutory laws.

**Class Notes:**

– **Key Elements for Party-List Nominee Qualification:**


– **Natural-born Filipino citizen**
– **Registered voter**
– **Resident of the Philippines for at least 1 year before the election**
– **Able to read and write**
– **25 years old or more (with specific age requirements for youth sector nominees)**
– **Bona fide member of the party or organization represented**
– **Relevant Constitutional Provision:** Section 17, Article VI of the Constitution.
– **Relevant Statutory Provision:** Section 9 & 13 of R.A. 7941 (Party-List System Act).

**Historical Background:**

– **Party-List Representation Introduction:**


– The party-list system was introduced as part of the 1987 Constitution, designed to ensure proportional
representation of marginalized and underrepresented sectors in Congress.
– **Role of HRET and COMELEC:**
– COMELEC initially registers and approves party-list groups’ participation in elections.
– The HRET serves as the final arbiter of all disputes regarding the qualifications of elected House
members, reflecting the broader checks and balances within the legislative branch.

The decision reaffirms the authority structure within the legislative electoral system, balancing initial
administrative vetting by COMELEC with adjudicative oversight by the HRET.

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