### Facts:
The case concerns the petition filed by private respondent Melanio Mauricio, Jr., to cancel the registration and accreditation of the ABC (Alliance for Barangay Concerns) Party-List. Mauricio alleged that ABC was a front for the religious organization Ang Dating Daan, disqualifying it under Section 6(1) of the Party-List System Act, R.A. No. 7941. The petition underwent several procedural stages, including a dismissal by the COMELEC Second Division citing procedural issues and substantial grounds, and the private respondent’s subsequent motions, culminating in the COMELEC en banc’s partial granting of a Motion for Reconsideration. This led to the reinstatement of the petition and orders for a hearing, which prompted ABC Party-List to file a special civil action for certiorari with the Supreme Court, alleging grave abuse of discretion by COMELEC.
### Issues:
1. Whether the COMELEC en banc had jurisdiction to entertain the petition for cancellation of ABC Party-List’s registration post-proclamation.
2. If the COMELEC maintained jurisdiction, did it commit grave abuse of discretion by scheduling a hearing for Mauricio’s petition despite prior opportunities to present his case?
3. Was the COMELEC en banc’s decision to not dismiss Mauricio’s petition despite procedural defects and perceived lack of merit an instance of grave abuse of discretion?
4. Did the COMELEC en banc exhibit grave abuse of discretion by treating ABC Party-List’s case differently from similar cases that were summarily dismissed?
### Court’s Decision:
The Supreme Court dismissed the petition, upholding that COMELEC en banc had jurisdiction to review the petition for cancellation of ABC Party-List’s registration based on allegations of being a religious front. The Court found no grave abuse of discretion in COMELEC’s handling of procedural issues or its decision to proceed with a hearing, emphasizing the importance of due process. The perceived disparity in treatment between this case and similar cases was not considered meritorious of demonstrating grave abuse of discretion.
### Doctrine:
The jurisdiction of the COMELEC over petitions for cancellation of political party registrations is enshrined in the Constitution and reflective in R.A. No. 7941. The right to due process necessitates the opportunity for both parties to present evidence and argue their cases adequately. The Supreme Court clarified that the COMELEC retains jurisdiction over the registration status of parties, while the HRET possesses jurisdiction over the qualifications of party-list representatives post-proclamation.
### Class Notes:
– **Jurisdiction of COMELEC vs. HRET**: COMELEC holds jurisdiction over parties and their registration, while HRET oversees the qualifications of elected representatives once proclaimed.
– **Due Process in Election-Related Petitions**: The necessity for a thorough hearing, ensuring parties can present their cases, is central to ensuring due process.
– **Doctrine of Separation of Powers**: The distinct roles and areas of jurisdiction between electoral bodies (COMELEC) and electoral tribunals (HRET) underscore the principles of separation of powers within the context of electoral contests.
– **Grave Abuse of Discretion**: Defined as a capricious, whimsical exercise of judgment that amounts to a lack or excess of jurisdiction; not found in the COMELEC’s actions within this case.
– **Procedural Compliance**: Substantial compliance with procedural requirements, particularly in administrative and electoral processes, may be deemed sufficient in ensuring the parties’ rights to due process are not infringed.
### Historical Background:
The case underscores the intricacies of the Philippine Party-List System, emphasizing the delicate balance between ensuring broad representation and preventing the misuse of the system for purposes contrary to the intent of the law such as masquerading religious groups as political entities. This decision further delineates the jurisdictional boundaries between COMELEC and HRET, ensuring that electoral disputes are adjudicated by the appropriate body.
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