JOSE L. ATIENZA, JR., MATIAS G.R. No. 188920 V. DEFENSOR, JR., RODOLFO G.
VALENCIA, DANILO E. SUAREZ,
SOLOMON R. CHUNGALAO,
HARLIN CAST-ABAYON, MELVIN G.
MACUSI and ELEAZAR P. QUINTO,
Petitioners, Present: Puno, C.J., Carpio, Corona, Carpio Morales,
Velasco, Jr., Nachura,
- versus - Leonardo-De Castro, Brion,
COMMISSION ON ELECTIONS,
MANUEL A. ROXAS II,
FRANKLIN M. DRILON and Promulgated: J.R. NEREUS O. ACOSTA,
Respondents. February 16, 2010 x ---------------------------------------------------------------------------------------- x
This petition is an offshoot of two earlier cases already resolved by the Court involving a leadership dispute within a political party. In this case, the petitioners question their expulsion from that party and assail the validity of the election of new party leaders conducted by the respondents.
Statement of the Facts and the Case
For a better understanding of the controversy, a brief recall of the preceding events is in order.
On July 5, 2005 respondent Franklin M. Drilon (Drilon), as erstwhile president of the Liberal Party (LP), announced his party’s withdrawal of support for the administration of President Gloria Macapagal-Arroyo. But petitioner Jose L. Atienza, Jr. (Atienza), LP Chairman, and a number of party members denounced Drilon’s move, claiming that he made the announcement without consulting his party.
On March 2, 2006 petitioner Atienza hosted a party conference to supposedly discuss local autonomy and party matters but, when convened, the assembly proceeded to declare all positions in the LP’s ruling body vacant and elected new officers, with Atienza as LP president. Respondent Drilon immediately filed a petition with the Commission on Elections (COMELEC) to nullify the elections. He claimed that it was illegal considering that the party’s electing bodies, the National Executive Council (NECO) and the National Political Council (NAPOLCO), were not properly convened. Drilon also claimed that under the amended LP Constitution, party officers were elected to a fixed three-year term that was yet to end on November 30, 2007.
On the other hand, petitioner Atienza claimed that the majority of the LP’s NECO and NAPOLCO attended the March 2, 2006 assembly. The election of new officers on that occasion could be likened to “people power,” wherein the LP majority removed respondent Drilon as president by direct action. Atienza also said that the amendments to the original LP Constitution, or the Salonga Constitution, giving LP officers a fixed three-year term, had not been properly ratified. Consequently, the term of Drilon and the other officers already ended on July 24, 2006.
On October 13, 2006, the COMELEC issued a resolution, partially granting respondent Drilon’s petition. It annulled the March 2, 2006 elections and ordered the holding of a new election under COMELEC supervision. It held that the election of petitioner Atienza and the others with him was invalid since the electing assembly did not convene in accordance with the Salonga Constitution. But, since the amendments to the Salonga Constitution had not been properly ratified, Drilon’s term may be deemed to have ended. Thus, he held...
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