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MAGDALO PARA SA PAGBABAGO v. COMELEC

FACTS:

Petitioner Magdalo sa Pagbabago (MAGDALO) filed a Petition for Registration with the COMELEC seeking its registration as a regional political party. The COMELEC Second Division denied the petition due to the involvement of Senator Trillanes and some members of the party in the Oakwood mutiny. MAGDALO filed a Motion for Reconsideration but it was also denied by the COMELEC En Banc. MAGDALO then filed a Petition for Certiorari with the Supreme Court, seeking to reverse the COMELEC Resolutions and to be granted a Certificate of Registration.

The case involves a petition for certiorari filed by Magdalo Para sa Pilipino (Magdalo) seeking to nullify the resolutions of the COMELEC denying their petition for registration as a regional political party. Magdalo argues that the COMELEC violated their constitutional right to due process and the presumption of innocence by prematurely concluding that the founders of Magdalo committed mutiny and other unlawful acts during the Oakwood incident. The COMELEC asserts that it had the power to assess the eligibility of MAGDALO for registration and accreditation as a political party, including determining whether they advocate the use of force. The court also discusses whether the case has been rendered moot and academic since it was intended for the 2010 elections but concludes that exceptions to mootness apply. The court then proceeds to rule on the issue of whether the COMELEC gravely abused its discretion in denying Magdalo's petition for registration. Lastly, the court discusses the constitutional and statutory mandates of the COMELEC in registering political parties.

The case involves the denial of the petition for registration of the political party MAGDALO by the COMELEC. MAGDALO sought to be registered as a party-list organization under the Party-List System Act. The COMELEC denied the petition on the basis of the Oakwood incident, a failed military coup in 2003. MAGDALO argued that the denial was based on mere speculation and conjecture, and constituted grave abuse of discretion. The COMELEC argued that it took judicial notice of the Oakwood incident, which was a matter of public knowledge.

ISSUES:

  1. Whether the Commission on Elections (COMELEC) committed grave abuse of discretion in taking judicial notice of the Oakwood incident.

  2. Whether the COMELEC committed grave abuse of discretion in finding that MAGDALO uses violence or unlawful means to achieve its goals.

  3. Whether the COMELEC committed grave abuse of discretion in treating the Oakwood standoff as a manifestation of MAGDALO's resort to violence or threats thereof to achieve its objectives.

  4. Whether the finding that MAGDALO seeks to achieve its goals through violence or unlawful means operated as a prejudgment of Criminal Case No. 03-2784.

  5. Whether or not the subsequent grant of amnesty to military personnel involved in the Oakwood standoff affects the evaluation of the Petition for Registration filed by MAGDALO.

  6. Whether or not the grant of amnesty violated the right of petitioner's members to a presumption of innocence.

  7. Whether or not the amnesty granted to members of the Magdalo group affects their disqualification from party registration.

  8. Whether or not the Commission on Elections (COMELEC) committed grave abuse of discretion in denying the petition for registration filed by Magdalo.

RULING:

  1. The COMELEC did not commit grave abuse of discretion in taking judicial notice of the Oakwood incident. The incident was widely known and extensively covered by the media, making it a proper subject of judicial notice. The COMELEC, being an administrative agency, is empowered to admit and give probative value to evidence commonly acceptable by reasonably prudent men, and to take notice of judicially cognizable facts.

  2. The COMELEC did not commit grave abuse of discretion in finding that MAGDALO uses violence or unlawful means to achieve its goals. The Oakwood incident, in which over 300 heavily armed military officers and enlisted men led by the founding members of MAGDALO took over Oakwood, displayed the use of violence. MAGDALO's objectives during the incident were to express dissatisfaction with the administration of former President Arroyo, divulge alleged corruption in the military, and demand the resignation of the President, her cabinet members, and top officials of the AFP and PNP. To achieve these goals, MAGDALO resorted to seizing a hotel occupied by civilians, marching in the premises with ammunitions, and planting explosives. These actions constituted clear acts of violence.

  3. The COMELEC did not commit grave abuse of discretion in treating the Oakwood standoff as a manifestation of MAGDALO's resort to violence or threats thereof to achieve its objectives. The deliberate brandishing of military power, use of full battle gear, display of ammunitions, and use of explosive devices created an alarming security risk to the public and preyed on the vulnerability of civilians. The totality of these acts fomented a threat of violence. The COMELEC was justified in considering these acts and treating them as indicative of MAGDALO's resort to violence or threats thereof.

  4. The finding that MAGDALO seeks to achieve its goals through violence or unlawful means did not operate as a prejudgment of Criminal Case No. 03-2784. The power of the COMELEC to register political parties and ascertain their eligibility is purely administrative in character. In exercising this authority, the COMELEC only needs to assess whether the party or organization pursues its goals by employing acts considered as violent or unlawful, not necessarily criminal in nature. The COMELEC's evaluation is limited to the examination of qualifications for registration. On the other hand, Criminal Case No. 03-2784 is a criminal action charging members of MAGDALO with coup d'état. The evidentiary threshold for criminal cases is proof beyond reasonable doubt, which is different from the evidentiary threshold of substantial evidence in administrative proceedings. Thus, the COMELEC's ruling in the registration case did not preempt the trial and decision of the court in the criminal case and did not violate the right to presumption of innocence.

  5. The subsequent grant of amnesty to military personnel involved in the Oakwood standoff does not affect the evaluation of the Petition for Registration filed by MAGDALO. The Court recognizes that the grant of amnesty is a public act that the courts should take judicial notice of. Amnesty extinguishes any criminal liability for acts committed in connection, incident or related to the Oakwood standoff. It also effects the restoration of civil and political rights or entitlements of the grantees, without prejudice to their civil liability for injuries or damages caused to private persons. The grant of amnesty does not change the evaluation of the Petition for Registration since it does not erase the occurrence of the Oakwood incident.

  6. Yes, the amnesty granted to members of the Magdalo group affects their disqualification from party registration. The amnesty granted by the President of the Philippines and concurred by both houses of Congress expressly provides that the amnesty covers all acts and omissions arising from the Oakwood incident, and that those granted amnesty shall be deemed not to have committed any crime or offense. Therefore, the events that transpired during the Oakwood incident can no longer be interpreted as acts of violence in the context of the disqualifications from party registration.

  7. No, the COMELEC did not commit grave abuse of discretion in denying the petition for registration filed by Magdalo. The COMELEC's denial was based on the fact that the Oakwood incident involved the use of violence, which is a ground for disqualification from party registration. However, in view of the subsequent amnesty granted to the members of Magdalo, the events that transpired during the Oakwood incident can no longer be considered acts of violence in the context of the disqualifications from party registration.

PRINCIPLES:

  • Judicial notice may be taken of matters that are of public knowledge or capable of unquestionable demonstration.

  • Administrative agencies are empowered to admit and give probative value to evidence commonly acceptable by reasonably prudent men, and to take notice of judicially cognizable facts.

  • Violence is the unjust or unwarranted exercise of force, usually accompanied by vehemence, outrage, or fury. It also denotes physical force unlawfully exercised against common right, laws, and public liberty.

  • An unlawful act is one that is contrary to law, and need not be a crime. The intent is not necessarily required for an act to be considered unlawful.

  • The power of the COMELEC to evaluate the eligibility of political parties is administrative in nature and is limited to determining whether the party pursues its goals through violence or unlawful means.

  • The evidentiary threshold for administrative proceedings is substantial evidence, while the evidentiary threshold for criminal cases is proof beyond reasonable doubt.

  • The findings and disposition in administrative proceedings do not necessarily result in the same disposition for criminal cases, even if they arise from the same set of facts.

  • The denial of a petition for registration as a political party does not violate the right to presumption of innocence, as political party registration is a privilege and not a right.

  • Amnesty is a general pardon that abolishes and puts into oblivion the offense itself. The person released by amnesty stands before the law precisely as though he had committed no offense.

  • Amnesty is a public act that the courts should take judicial notice of. Pardon, on the other hand, is a private act that must be pleaded and proved by the person pardoned.

  • Amnesty granted by the President and concurred by both houses of Congress has the effect of erasing the criminal liability of the persons granted amnesty and should be given full effect.

  • The purpose of amnesty is to promote an atmosphere conducive to attaining peace and reconciliation, and to provide a just, comprehensive, and enduring peace.

  • The use of violence is a ground for disqualification from party registration. However, if the use of violence is covered by an amnesty, it can no longer be considered as a ground for disqualification.