TL;DR — Ruling
WHEREFORE , premises considered, the COMMISSION En Banc RESOLVED , as it hereby RESOLVES , to DISMISS the instant Petition for LACK OF MERIT . SO ORDERED . [21] (Emphasis in original) The COMELEC En Banc stated that the main issue in this case is who between the parties represent the incumbent officials of the PFP.
WHEREFORE , premises considered, the COMMISSION En Banc RESOLVED , as it hereby RESOLVES , to DISMISS the instant Petition for LACK OF MERIT . SO ORDERED . [21] (Emphasis in original) The COMELEC En Banc stated that the main issue in this case is who between the parties represent the incumbent officials of the PFP. To resolve this issue, the COMELEC stated that it must first determine: (1) Which between the 2018 and 2022 Constitutions and By-laws of PFP is in effect; and (2) Whether party officers exercise holdover authority under PFP's prevailing Constitution and By-laws. [22] First , the COMELEC established that it has jurisdiction to decide the case, pursuant to its administrative powers under the Constitution. It stated that its power to register political parties necessarily involves the determination of the persons who must act on such parties' behalf. The COMELEC further noted that during the June 4, 2024 hearing, the parties agreed that the COMELEC En Banc has jurisdiction to hear and decide the case at the first instance, in the exercise of its administrative powers. [23] Second , the COMELEC En Banc disposed of Verceles and Rodriguez' argument in their Motion to Admit Petitioner's Reply to Respondent's Memorandum that the issue of Tamayo, et al.'s holdover authority may not be inquired into, as the COMELEC has limited jurisdiction in deciding issues in intra-party disputes. The COMELEC clarified that it did not waive the issue of holdover capacity, and in fact directed both parties to address the same in their respective memoranda. The COMELEC stated that the determination of the applicability of holdover authority within the internal rules of the PFP is a material issue in its disposition of the intra-party dispute. [24] The COMELEC clarified that it is not improper or outside its authority to inquire into the applicability of the principle of holdover capacity, as may be necessary to settle the intra-party dispute. [25] On the merits, the COMELEC first dealt with the issue of which between the two sets of Constitutions and By-laws is governing. Based on the COMELEC's review of the records, it found that Tamayo, et al. were able to prove with substantial evidence that the 2022 Constitution and By-Laws of the PFP are the more recent and authoritative governing documents of the party. [26] The COMELEC noted that these documents were duly submitted to Commission and are on the COMELEC's record as the prevailing rules governing the operations and leadership structure of the PFP. [27] The COMELEC further noted that, at the time these documents were submitted, Verceles and Rodriguez were incumbent officers of the PFP, occupying high-level positions. They interposed no objection to the submission of the 2022 Constitution and By-Laws in time for the 2022 National and Local Elections. In other words, Verceles and Rodriguez did not dispute that Tamayo, et al. had the authority to file and sign said documents on behalf of the PFP at the time they