The Supreme Court ruled that the Commission on Elections (COMELEC) did not gravely abuse its discretion in dismissing the petition to nullify the Supreme Assembly of Abakada Guro Partylist (ABAKADA). The Court emphasized the importance of respecting the internal affairs of political parties and the COMELEC’s role in resolving leadership disputes, finding no basis to interfere with COMELEC’s decision to uphold the assembly’s validity. This means that COMELEC has the authority to ensure party-list organizations adhere to their constitutions while also respecting the democratic will of their members, particularly when leadership disputes arise.

When Internal Rifts Threaten a Party’s Foundation: Who Decides ABAKADA’s Destiny?

This case revolves around a leadership struggle within ABAKADA Guro Partylist. Samson S. Alcantara, along with other founding members, questioned the validity of a Supreme Assembly convened on February 6, 2010. This assembly resulted in their ouster from leadership positions and their expulsion from the party. Alcantara et al. argued that the assembly was not convened in accordance with the party’s Constitution and By-Laws (CBL), specifically because the notices were not authorized by the President (Alcantara) and the National Executive Board, and that many participants were not legitimate members.

The respondents, led by Jonathan de la Cruz and Ed Vincent Albano, countered that the assembly was necessary because Alcantara had failed to convene the Supreme Assembly as required by the CBL, and that they had made multiple attempts to urge him to do so. They maintained that the general membership had the right to take the initiative and call for the assembly when the elected officials refused to act. This internal conflict brought to the forefront the tension between adhering strictly to procedural rules and ensuring democratic accountability within a political party. The central legal question was whether the COMELEC gravely abused its discretion in upholding the validity of the Supreme Assembly, despite the petitioners’ claims of procedural violations and questionable membership status of the participants.

The COMELEC, in its rulings, dismissed the petition, finding that the holding of the assembly was long overdue and that the respondents had good cause to initiate the meeting due to Alcantara’s failure to convene it. The COMELEC En Banc further stated that the petitioners failed to prove that the Supreme Assembly delegates were non-members of the party. The core of the dispute centered on the interpretation and application of ABAKADA’s CBL, particularly regarding the convening of the Supreme Assembly and the requirements for membership. Alcantara et al. argued that only those individuals with approved membership applications should be considered legitimate members, while the respondents contended that many more individuals had become members since the party’s inception.

The Supreme Court, in its decision, emphasized the COMELEC’s authority to resolve party leadership disputes. The Court stated that it would only interfere with the COMELEC’s actions if the petitioners could establish that the COMELEC acted without or in excess of jurisdiction or with grave abuse of discretion amounting to lack or excess of jurisdiction. The Court also made a very important point: “By grave abuse of discretion is generally meant the capricious and whimsical exercise of judgment equivalent to lack of jurisdiction. Mere abuse of discretion is not enough. It must be grave, as when it is exercised arbitrarily or despotically by reason of passion or personal hostility.”

The Court found that the petitioners failed to meet this burden. The Court noted that the petitioners only established the group’s membership as of 2003, failing to account for the group’s actual membership as of 2009, immediately prior to the Supreme Assembly. The Court also pointed out that the President or the National Executive Board did not have the exclusive authority to approve applications for party membership, as such applications were approved by the membership council at the municipal, city, provincial, or regional levels. Given this membership structure, Alcantara’s affidavit and the approved membership applications from 2003 were insufficient to support the petition’s claim.

Building on this principle, the Court highlighted the freedom of political parties to conduct their internal affairs pursuant to their constitutionally-protected right to free association. This includes the determination of the individuals who shall constitute the association and the officials who shall lead the party in attaining its goals. The Court quoted Section 8, Article III of the 1987 Constitution and cited *Valencia v. Peralta*, G.R. No. L-47771, March 11, 1978. The court said that political parties constitute a basic element of our democratic institutional apparatus and help stimulate public participation in the political arena.

Furthermore, the Court emphasized that if the validity of the Supreme Assembly depended solely on the person who calls the meeting and sends the notice (Alcantara and Dabu), then the petitioners could perpetuate themselves in power, violating the very constitution they cited. In line with this concept, the Supreme Court held:

The petitioners’ argument is contrary to these basic tenets. If the validity of the Supreme Assembly would completely depend on the person who calls the meeting and on the person who sends the notice of the meeting – who are petitioners Alcantara and Dabu themselves – then the petitioners would be able to perpetuate themselves in power in violation of the very constitution whose violation they now cite. This kind of result would strike at the heart of political parties as the “basic element of the democratic institutional apparatus.” This potential irregularity is what the COMELEC correctly prevented in ruling for the dismissal of the petition.

The Court emphasized that ABAKADA’s constitution expressly requires the convening of the Supreme Assembly once every three years to elect the members of the National Executive Board. As the COMELEC correctly observed, ABAKADA’s constitution expressly requires the convening of the Supreme Assembly once every three years for purposes of (i) electing the members of the National Executive Board – the governing body of ABAKADA – headed by petitioner Alcantara as President.The respondents communicated with Alcantara to urge him to call for and assemble the leaders and members of the party for the coming May 2010 elections, but Alcantara failed to act. The COMELEC gave primacy to the substance of democratic accountability within the party over matters of procedure in ABAKADA’s CBL, especially after the general membership had spoken.

FAQs

What was the key issue in this case?	The key issue was whether the COMELEC committed grave abuse of discretion in upholding the validity of the Supreme Assembly of ABAKADA Guro Partylist, despite claims that it was not convened in accordance with the party’s CBL. The petitioners argued that the meeting was illegal because many participants were not legitimate members and the notices were not properly authorized.
What is the significance of the Supreme Assembly in ABAKADA?	The Supreme Assembly is the highest governing body of ABAKADA, responsible for electing the members of the National Executive Board and amending the party’s CBL. According to ABAKADA’s constitution, it should be convened every three years, but no assembly had been held since ABAKADA’s inception in 2003.
What did the COMELEC rule regarding the membership of the Supreme Assembly participants?	The COMELEC ruled that the petitioners failed to prove that the attendees in the Supreme Assembly were not legitimate members of the party. The COMELEC reasoned that the petitioners only presented evidence of membership as of 2003 and did not account for new members who may have joined since then.
What is the role of the COMELEC in party leadership disputes?	The COMELEC has the authority to resolve party leadership disputes and determine who are the legitimate officers of a party-list group. This authority is derived from its power to register political parties and enforce laws related to elections.
What is grave abuse of discretion?	Grave abuse of discretion is the capricious and whimsical exercise of judgment equivalent to lack of jurisdiction. It is not mere abuse of discretion, but rather an abuse that is so patent and gross as to amount to an evasion of a positive duty or a virtual refusal to perform a duty.
How does the right to free association relate to political parties?	The constitutionally-protected right to free association allows political parties to conduct their internal affairs, including determining their membership and choosing their leaders. This right is essential for political parties to function effectively in a democratic society.
Why did the Court dismiss the petition?	The Court dismissed the petition because the petitioners failed to establish that the COMELEC acted with grave abuse of discretion. The Court found that the COMELEC’s rulings were supported by substantial evidence and that the COMELEC properly considered the party’s CBL and the circumstances surrounding the Supreme Assembly.
What was the effect of the respondents’ actions?	The respondents’ actions resulted in the ouster of Alcantara and his allies from their leadership positions and their expulsion from the party. Jonathan de la Cruz and Ed Vincent Albano were elected as the new President and Secretary-General, respectively.

In conclusion, the Supreme Court’s decision reinforces the principle of party autonomy and the COMELEC’s role in resolving internal disputes within political parties. The Court’s emphasis on the need for petitioners to demonstrate grave abuse of discretion highlights the high threshold for judicial intervention in such matters. The decision underscores the importance of respecting the democratic processes within political parties and the need for parties to adhere to their own constitutions while also ensuring accountability to their members.

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: SAMSON S. ALCANTARA, ET AL. VS. COMELEC, ET AL., G.R. No. 203646, April 16, 2013