G.R. No. 206952 : OCTOBER 22, 2013 ABANG LINGKOD L INGKOD PARTY PARTY-LIST -LIST (ABANG LINGKOD), P!"!"o#$ P!" !"o#$,, %. CO&&ISSION CO&&I SSION ON ELECTIONS, R'o##!'. REYES, *.: +ACTS: ABANG LINGKOD is a sectoral organization that represents the interests of peasant farmers and sherfolks, and was registered registered nder the part!"list s!stem on Decem#er $$, $%%&' It failed to o#tain the nm#er of (otes needed in the )a! $%*% elections for a seat in the +ose of epresentati(es' On Agst *-, $%*$, ABANG LINGKOD, in compliance with the .O)/L/. Agst &, $%*$ resoltion, led with the .O)/L/. pertinent docments to pro(e its contining compliance with the re0irements nder 'A' No' 1&2*' In a esoltion dated No(em#er 1, $%*$, the .O)/L/. /n Banc cancelled ABANG LINGKOD registration as a part!"list grop' It pointed ot that ABANG LINGKOD failed to esta#lish its track record in plifting the case of the marginalized and nderrepresented3 that it merel! o4ered photographs of some alleged acti(ities it condcted after the )a! $%*% elections' ABANG LINGKOD eld a petitioner for certiorari alleging that the .O)/L/. gra(el! a#sed its discretion in cancelling its registration nder the part!"list s!stem' 5he said petition was consolidated with the separate petitions led #! 6* other part!"list grops whose registration were cancelled or who were denied registration nder the part!"list s!stem' 5he said part!"list grops, inclding ABANG LINGKOD, were a#le to o#tain stats 0o ante orders from the cort' 5he .ort remanded remanded to the .O)/L/. .O)/L/. the cases of pre(iosl! pre(iosl! registered registered part!"list part!"list grops, grops, inclding that of ABANG LINGKOD, to determine whether the! are 0alied nder the part!"list s!stem prsant to the new parameters laid down #! the .ort and, in the a7rmati(e, #e allowed to participate in the )a! $%*8 part!"list elections' On )a! *%, $%*8, the .O)/L/. issed the herein assailed esoltion, which, inter alia, a7rmed the cancellation of ABANG LINGKOD9s registration nder the part!"list s!stem' 5he .O)/L/. issed the esoltion esoltion dated )a! *%, $%*8 sans an! smmar! e(identiar! hearing, citing the pro:imit! of the )a! *8, $%*8 elections as the reason therefor' On )a! *$, $%*8, ABANG LINGKOD soght a reconsideration of the .O)/L/.9s esoltion dated )a! *%, $%*8' +owe(er, on )a! *6, $%*8, ABANG LINGKOD withdrew the motion for reconsideration recons ideration it led with the .O)/L/. and, instead, institted the instant petition with this .ort, alleging that there ma! not #e enogh time for the .O)/L/. to pass pon the merits of its motion for reconsideration considering that the election retrns were alread! #eing can(assed and consolidated #! the .O)/L/.'
ISSE: !$ o$ #o! ABANG LINGKOD /' #" $o''
4ELD: BANG LINGKOD /' #o! #" o $o''. POLITICAL LA: "#"'!$!"% $o'' 5he essence of de process process is simpl! simpl! an opportnit! opportnit! to #e heard heard or as applied applied to administrati(e administrati(e or 0asi";dicial proceedings, proceedings, an opportnit! to e:plain one9s side or an opportni opportnit! t! to seek reconsideration of the action or rling complained of' A formal or trial t!pe hearing is not at all times and in all instances essential' 5he re0irements are satised when the parties are a4orded fair and reasona#le opportnit! to e:plain their side of the contro(ers! at hand'
that the .O)/L/. had a4orded ABANG LINGKOD s7cient opportnit! to present e(idence esta#lishing its 0alication as a part!"list grop' It was notied throgh esoltion No' &6*8 that its registration was to #e re(iewed #! the .O)/L/.' 5hat ABANG LINGKOD was a#le to le its )anifestation of Intent and other pertinent docments to pro(e its contining compliance with the re0irements nder 'A' No' 1&2*, which the .O)/L/. set for smmar! hearing on three separate dates, #elies its claim that it was denied de process' 5here was no necessit! for the .O)/L/. to condct frther smmar! e(identiar! hearing to assess the 0alication of ABANG LINGKOD prsant to Atong =aglam' ABANG LINGKOD9s )anifestation of Intent and all the e(idence addced #! it to esta#lish its 0alication as a part!" list grop are alread! in the possession of the .O)/L/.' 5hs, condcting frther smmar! e(identiar! hearing for the sole prpose of determining ABANG LINGKOD9s 0alication nder the part!"list s!stem prsant to Atong =aglamwold ;st #e a sper>it!' .ontrar! to ABANG LINGKOD9s claim, the .ort, in Atong =aglam, did not categoricall! re0ire the .O)/L/. to condct a smmar! e(identiar! hearing for the prpose of determining the 0alications of the petitioners therein prsant to the new parameters for screening part!"list grops'
POLITICAL LA: #77!"o# o $!8-7"'! $"'!$!"o# .ort nds that the .O)/L/. gra(el! a#sed its discretion in cancelling the registration of ABANG LINGKOD nder the part!"list s!stem' 5he .O)/L/. a7rmed the cancellation of ABANG LINGKOD9s registration on the grond that it declared ntrthfl statement in its #id for accreditation as a part!"list grop in the )a! $%*8 elections, pointing ot that it deli#eratel! s#mitted digitall! altered photographs of acti(ities to make it appear that it had a track record in representing the marginalized and nderrepresented' /ssentiall!, ABANG LINGKOD9s registration was cancelled on the grond that it failed to addce e(idence showing its track record in representing the marginalized and nderrepresented' 'A' No' 1&2* did not re0ire grops intending to register nder the part!"list s!stem to s#mit proof of their track record as a grop' 5he track record re0irement was onl! imposed in Ang Bagong Ba!ani where the .ort held that national, regional, and sectoral parties or organizations seeking registration nder the part!"list s!stem mst pro(e throgh their, inter alia, track record that the! trl! represent the marginalized and nderrepresented' In Atong =aglam, the .ort has modied to a great e:tent the ;risprdential doctrines on who ma! register nder the part!"list s!stem and the representation of the marginalized and nderrepresented' ?or prposes of registration nder the part!"list s!stem, national or regional parties or organizations need not represent an! marginalized and nderrepresented sector3 that representation of the marginalized and nderrepresented is onl! re0ired of sectoral organizations that represent the sectors stated nder @ection 6 of 'A' No' 1&2* that are, #! their natre, economicall! marginalized and nderrepresented' .ontrar! to the .O)/L/.9s claim, sectoral parties or organizations, sch as ABANG LINGKOD, are no longer re0ired to addce e(idence showing their track record, i'e' proof of acti(ities that the! ha(e ndertaken to frther the case of the sector the! represent' Indeed, it is enogh that their principal ad(ocac! pertains to the special interest and concerns of their sector' Otherwise stated, it is s7cient that the ideals represented #! the sectoral organizations are geared towards the case of the sectors, which the! represent' Dissenting, )r' stice Leonen, howe(er, maintains that parties or organizations intending to register nder the part!"list s!stem are still re0ired to present a track record notwithstanding the .ort9s prononcement in Atong =aglam3 that the track record that wold ha(e to #e presented wold onl! di4er as to the natre of their groporganization' +e opines that sectoral organizations mst pro(e their links with the marginalized and nderrepresented while national or regional parties or organizations mst show that the! ha(e #een e:isting as a #ona de organization'