**Facts:**
1. **November 12, 2008:** The Commission on Elections (COMELEC) issued Resolution No. 8514, setting the period of continuing voter registration using biometrics processes from December 2, 2008, to December 15, 2009, excluding the Autonomous Region of Muslim Mindanao (ARMM).
2. **February 12, 2009:** COMELEC issued Resolution No. 8585, adjusting the deadline for voter registration to October 31, 2009, instead of December 15, 2009.
3. Despite public clamor for an extension of the new deadline, COMELEC did not extend the registration period, citing the need to prepare for automated elections.
4. **October 30, 2009:** Kabataan Party-list Representative Raymond V. Palatino, along with other petitioners, filed a Petition for Certiorari and Mandamus before the Supreme Court, challenging the validity of Resolution No. 8585 and seeking its declaration as null and void. Petitioners argued potential disenfranchisement of millions of Filipino voters, particularly the youth demographic based on National Statistics Office projections.
5. Petitioners claimed that Resolution No. 8585 encroached on the legislative power of Congress, which prescribed a system of continuing voter registration under Section 8 of Republic Act No. 8189 (The Voter’s Registration Act of 1996).
**Issues:**
1. Whether COMELEC Resolution No. 8585 violated Section 8 of Republic Act No. 8189 by setting an early deadline for voter registration.
2. Whether COMELEC had the authority to fix the registration deadline at October 31, 2009, instead of following the 120-day pre-election registration prohibition stipulated by law.
3. Whether the denial of the extension of voter registration disenfranchised potential voters, especially those in the youth sector.
**Court’s Decision:**
1. **Violation of RA No. 8189:** The Supreme Court held that COMELEC Resolution No. 8585, by setting the voter registration deadline to October 31, 2009, circumvented the legislative intent of RA 8189. The law mandates daily registration during regular office hours except for the period starting 120 days before a regular election. Therefore, the resolution was deemed unconstitutional as it altered the system of continuing voter registration beyond the prescribed statutory boundaries.
2. **COMELEC’s Authority:** While COMELEC has the power under both RA 6646 and RA 8436 to fix other dates for pre-election acts if the prescribed timelines cannot be reasonably observed, this authority does not extend to altering the clear mandate of RA 8189 regarding voter registration periods. The Supreme Court opined that the power to adjust pre-election dates does not permit undermining statutory provisions ensuring the right of suffrage.
3. **Potential Disenfranchisement:** Given that the date of the petition filing and the requested extension fell outside the 120-day prohibitive period (October 30, 2009, and until January 9, 2010), the Court found no legal barrier preventing the extension of voter registration. The Court emphasized the paramount importance of the right of suffrage and its protection afforded by both the Constitution and statutory law.
**Doctrine:**
The case reaffirmed the principles:
– The crucial nature of the right to suffrage within constitutional democracy.
– Judicial duty to harmonize laws, with the presumption against inconsistency and implied repeal.
– The provisions of Section 8 of RA 8189, ensuring continuing voter registration except during the defined prohibitive period, cannot be unilaterally amended by administrative resolutions such as COMELEC’s.
**Class Notes:**
– **Right of Suffrage:** Constitution, Article V, Sections 1 and 2.
– **Continuing Voter Registration Mandate:** Republic Act No. 8189, Section 8.
– **Periodic Extent of Administrative Power:** Republic Act No. 6646, Section 29; Republic Act No. 8436, Section 28.
– **Judicial Interpretation:** Courts must harmonize laws, and the legislative intent must prevail over administrative adjustments.
– **Voter Registration Prohibitive Period:** 120 days before a regular election (RA 8189).
– **Paramount Constitutional Rights:** Right to vote and participate in elections free from unjust administrative obstacles.
**Historical Background:**
This case unfolded in a critical period when the Philippines was transitioning to automated elections. The case epitomized the tension between administrative expedience in election preparations and the need to maximize the enfranchisement of eligible voters. It reflects broader historical efforts to safeguard electoral integrity while upholding citizen participation in democratic processes. The case demonstrates the evolving landscape of election laws and the judiciary’s role in ensuring these laws are faithfully implemented to protect fundamental democratic rights.
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