View full case

MANUEL T. DE GUIA v. COMELEC

FACTS:

Manuel T. De Guia, an incumbent Member of the Sangguniang Bayan of the Municipality of Parañaque, challenges the validity and enforcement of the COMELEC's resolutions on the apportionment of seats in the Sangguniang Panlalawigan and Sangguniang Bayan. The petitioner argues that the election of members of the Sangguniang Bayan by district should not apply to the May 11, 1992 elections, contrary to the COMELEC's interpretation of the law. The petitioner filed a motion for clarification, which the Commission affirmed in a subsequent resolution. The COMELEC's resolutions divided Parañaque and other municipalities in the Metro Manila Area into two districts for the purpose of electing members of the Sangguniang Bayan. The Court acknowledges the petitioner's lack of locus standi but decides to address the substantive controversy given its importance.

ISSUES:

  1. Whether petitioner has standing to file the petition for certiorari and prohibition

  2. Whether respondent COMELEC validly interpreted Sec. 3 of R.A. 7166 regarding the election of members of the Sangguniang Bayan by district in the May 11, 1992 elections

RULING:

  1. The Court brushes aside the question of procedural infirmity and recognizes petitioner's locus standi due to the importance of the issue involved, as it concerns the political exercise of qualified voters affected by the apportionment. Even though petitioner does not allege that he is running for reelection or that he is prejudiced by the election by district in Parañaque, the petition is treated as one of declaratory relief.

  2. The COMELEC's interpretation of Sec. 3 of R.A. 7166, that the election of members of the Sangguniang Bayan by district in the Metro Manila Area shall apply in the May 11, 1992 elections, is upheld. The Court finds no ambiguity in the provision and holds that the elected members of the Sangguniang Bayan mentioned in par. (c) should be elected by district in the said elections.

PRINCIPLES:

  • The petitioner must have locus standi or standing in order to file a petition.

  • The Court may overlook procedural infirmities if the petition involves important issues.

  • The interpretation of a statute by an administrative agency is accorded great weight if it is not contrary to law or the Constitution.

  • The Court may uphold the interpretation of an administrative agency if it finds no ambiguity in the provision being interpreted.