In a ruling with significant implications for Philippine elections, the Supreme Court upheld the constitutionality of Republic Act No. 10367 (RA 10367), also known as the Biometrics Law. This law mandates biometric voter registration, requiring voters to have their fingerprints, photos, and signatures digitally recorded. The Court found that this requirement does not violate the right to suffrage. Instead, it is a reasonable regulation designed to ensure clean, credible elections by preventing fraud and maintaining an updated voter list, thereby strengthening the integrity of the democratic process. This means that voters must comply with biometric registration to avoid deactivation, but also reinforces the state’s power to regulate elections for the greater public good.

The No Bio, No Boto Battle: Does Biometrics Validation Violate Suffrage?

The case of Kabataan Party-List v. Commission on Elections arose as a challenge to RA 10367 and related COMELEC resolutions. Petitioners argued that the biometrics validation requirement imposed an additional and unconstitutional qualification on the right to vote. They claimed that deactivation for non-compliance effectively disenfranchised voters, particularly the youth and marginalized sectors, without due process. In essence, the legal question before the Supreme Court was whether mandatory biometrics registration, with the penalty of deactivation for non-compliance, infringed upon the constitutional right to suffrage.

The Supreme Court anchored its decision on the understanding that the right to vote, while fundamental, is not absolute. The Court emphasized that suffrage is a right created and regulated by law, stating,

“[t]he right to vote is not a natural right but is a right created by law. Suffrage is a privilege granted by the State to such persons or classes as are most likely to exercise it for the public good.”

The 1987 Constitution, in Article V, Section 1, outlines the qualifications for suffrage: citizenship, age, and residency. Crucially, it prohibits imposing “literacy, property, or other substantive requirement[s]” on the exercise of this right. The debate centered on whether biometrics validation constituted such a prohibited substantive requirement.

The petitioners likened biometrics validation to the historically discriminatory requirements of literacy and property ownership, which were eliminated to broaden the electoral base. However, the Court distinguished between a qualification and a procedural requirement. Registration, including biometrics validation, was deemed a procedural regulation, not a substantive qualification. The Court cited Yra v. Abaño, stating that “Registration regulates the exercise of the right of suffrage. It is not a qualification for such right.” As such, the state has the authority to regulate the registration process to ensure fair and accurate elections.

Building on this principle, the Court emphasized that RA 10367 aimed to “establish a clean, complete, permanent and updated list of voters through the adoption of biometric technology.” By requiring biometrics validation, the COMELEC sought to prevent voter fraud, such as multiple registrations and the casting of ballots in the names of deceased individuals. The penalty of deactivation for non-compliance applied neutrally to all voters, dispelling the petitioners’ claim of creating an artificial class of voters. The Court observed that non-compliance simply led to the prescribed consequences, which is within the State’s power to enforce legitimate election regulations.

The Court addressed the petitioners’ argument that biometrics validation failed the strict scrutiny test, which requires a compelling state interest and narrowly tailored means. The Court held that the law indeed served a compelling state interest: ensuring orderly, honest, and credible elections. The biometrics requirement helped to combat electoral fraud and ensure that election results genuinely reflected the will of the people. Furthermore, the Court found that biometrics validation was the least restrictive means of achieving this goal.

The Court highlighted the COMELEC’s efforts to make the validation process accessible and convenient, including setting up satellite registration offices and conducting public information campaigns. The procedure for biometrics validation was straightforward: voters needed to appear personally, present identification, and have their biometric data recorded. The Court emphasized that validation was a one-time requirement, effective for subsequent elections as long as the voter remained active. Those deactivated could apply for reactivation. Therefore, the regulation was narrowly tailored and promoted the compelling state interest without unduly burdening the right to suffrage.

The petitioners also argued that RA 10367 and COMELEC resolutions violated procedural due process due to short notice periods and the summary nature of deactivation proceedings. However, the Court found that the COMELEC had taken sufficient measures to inform the public. RA 10367 was published well in advance, and the COMELEC conducted extensive public information campaigns. Affected voters were notified of the deactivation proceedings and given the opportunity to object. The Court acknowledged the urgency of finalizing the voters’ list for the upcoming elections, justifying the summary nature of the proceedings while ensuring that voters had a chance to be heard.

In rejecting the argument that experiences with biometrics in other countries served as a warning, the Court stated,

“[P]olicy matters are not the concern of the Court… It is not for this Court to look into the wisdom or propriety of legislative determination.”

The Supreme Court deferred to the legislature’s policy choices in combating electoral fraud through biometrics registration. The wisdom or practicality of the law, the Court held, was a matter for legislative judgment, not judicial review.

Ultimately, the Supreme Court upheld the constitutionality of RA 10367 and the COMELEC resolutions. By requiring biometric voter registration, the state aimed to enhance the integrity of elections, combat fraud, and ensure that the right to vote is exercised by qualified individuals. The Court balanced the fundamental right to suffrage with the state’s legitimate interest in regulating elections for the public good.

FAQs

What was the key issue in this case?	The key issue was whether the mandatory biometrics voter registration requirement under RA 10367, with the penalty of deactivation for non-compliance, violated the constitutional right to suffrage.
What is biometrics validation?	Biometrics validation is the process of collecting and recording a voter’s unique physical characteristics, such as fingerprints, photos, and signatures, in a digital format to verify their identity.
What happens if a voter does not comply with biometrics validation?	Voters who fail to comply with the biometrics validation requirement may have their registration records deactivated, preventing them from voting in elections until they reactivate their registration.
Is biometrics validation a new requirement?	While voter registration has always been a requirement, the biometrics component was institutionalized to build on RA 8189 (Voter’s Registration Act of 1996) to enhance the integrity and accuracy of voter lists.
Why did the COMELEC implement the biometrics validation requirement?	The COMELEC implemented the requirement to establish a clean, complete, and updated list of voters by preventing voter fraud, such as multiple registrations and the casting of ballots in the names of deceased individuals.
What did the petitioners argue in this case?	The petitioners argued that biometrics validation imposed an additional and unconstitutional qualification on the right to vote, violating due process and disenfranchising voters without a compelling state interest.
What was the Court’s ruling?	The Court ruled that biometrics validation is a reasonable regulation, not a qualification, and serves a compelling state interest in ensuring fair and accurate elections; therefore, it is constitutional.
What is the effect of this ruling?	The ruling reinforces the state’s authority to regulate elections for the public good, provided such regulations are reasonable, neutrally applied, and do not impose prohibited substantive requirements.

The Supreme Court’s decision in Kabataan Party-List v. COMELEC affirms the importance of balancing individual rights with the state’s responsibility to conduct credible elections. By upholding the constitutionality of mandatory biometrics voter registration, the Court has provided a clear framework for ensuring the integrity of the electoral process. This ruling underscores the significance of voter registration regulations in safeguarding democracy and preventing electoral fraud.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: KABATAAN PARTY-LIST vs. COMMISSION ELECTIONS, G.R. No. 221318, December 16, 2015