V.C. CADANGEN vs.
COMELEC
G.R. no. 177179
June 5, 2009
NACHURA, J.
Facts:
On September 13, 2006, petitioner Alliance of Civil Servants, Inc.
filed a petition for registration as a sectoral organization under R.A.
7941 or the Party-list System Act. It claimed that it had been in
existence since December 2004 and It sought to represent past and
present government employees in the party-list system. On December
11, 2006, the Comelec second division issued an order requiring Civil
Servants to file a memorandum that would prove its existence
nationwide, track record, financial capability to wage a nationwide
campaign, platform of government, officers and membership, and
compliance with the provisions of the party list system act and the
eight point guideline laid down by the Supreme Court. Civil Servants
filed the required memorandum and while its petition for registration
is pending, it also filed a manifestation of intent to participate in the
May 14, 2007 elections.
On February 13, 2007, the Comelec second division issued a
resolution denying Civil servants’ petition for registration. The
Comelec en banc affirmed the decision of the Second division citing
the lack of evidence to back the petitioner’s claim of existence
nationwide. Left with no other recourse, petitioner filed the case
praying for the issuance of a writ of certiorari to nullify the resolution
of the Comelec and a writ of mandamus to command the later to
register the Civil servants as a sectoral organization.
Issues:
Whether or not the Comelec gravely abused its discretion by denying
the petition for registration by the petitioner.
Whether or not the petition for certiorari is valid.
Held:
No. The registration of a party, organization, or coalition under R.A.
7941, the Comelec may require the submission of any relevant
information; and it may refuse, after due notice and hearing, the
registration of any national, regional or sectoral party, organization
and coalition based on any grounds enumerated in Sec. 6 of RA 7941.
The Comelec found that petitioner made an untruthful statement in
the pleadings and documents submitted.
No. The court emphasized that the sole function of a writ of certiorari
is to address issues of want jurisdiction or abuse of discretion and it
does not include a review of the tribunal’s evaluation of the evidence.
The findings of fact made by the Comelec, or by any other
administrative body exercising expertise in its particular field of
competence, are binding on the Court. The Court’ function, as
mandated by Sec. 1, Article VIII of the 1987 Constitution, is merely
to check whether or not the governmental branch or agency has gone
beyond the constitutional limits of its jurisdiction, not that it erred
or has different view. It has no authority to inquire into what it thinks
is apparent error.