Atienza vs COMELEC

Facts:
Respondent Franklin M. Drilon president of the Liberal Party (LP), announced his partys
withdrawal of support for the adinistration of President !loria Macapa"al#$rroyo. %ut
petitioner &ose L. $tien'a, &r., LP (hairan, and a nuber of party ebers denounced
Drilons o)e. *n March +, +,,- $tien'a hosted a party conference to supposedly discuss
local autonoy and party atters but the assebly proceeded to declare all positions in the
LPs rulin" body )acant and elected new o.cers, with $tien'a as LP president. Respondent
Drilon iediately /led a petition with the (*M0L0( to nullify the elections. 1e claied that
it was ille"al considerin" that the partys electin" bodies, the 2ational 03ecuti)e (ouncil
(20(*) and the 2ational Political (ouncil (2$P*L(*), were not properly con)ened. Drilon
also claied that under the aended LP (onstitution party o.cers were elected to a /3ed
three#year ter that was yet to end on 2o)eber 4,, +,,5. $tien'a claied that the
a6ority of the LPs 20(* and 2$P*L(* attended the March +, +,,- assebly. 7he election
of new o.cers could be likened to 8people power,9 wherein the LP a6ority reo)ed
respondent Drilon as president by direct action. $tien'a also said that the aendents to
the ori"inal LP (onstitution had not been properly rati/ed. (onse:uently, the ter of Drilon
and the other o.cers already ended on &uly +;, +,,-. (*M0L0( issued a resolution partially
"rantin" Drilons petition. <t annulled the March +, +,,- elections and ordered the holdin" of
a new election under (*M0L0( super)ision. <t held that the election of petitioner $tien'a
and the others with hi was in)alid since the electin" assebly did not con)ene in
accordance with the =alon"a (onstitution. %ut, since the aendents to the =alon"a
(onstitution had not been properly rati/ed, Drilons ter ay be deeed to ha)e ended.
7he (ourt held in a petition /led by both parties a"ainst (*M0L0( that the latter had
6urisdiction o)er the intra#party leadership dispute> that the =alon"a (onstitution had been
)alidly aended> and that Drilons ter as LP president was to end only on 2o)eber 4,,
+,,5. 7he LP held a 20(* eetin" to elect new party leaders before respondent
Drilons ter e3pired. Fifty#nine 20(* ebers out of the ?5 attended. %efore the election
se)eral persons sou"ht to clarify their ebership status and raised issues re"ardin" the
coposition of the 20(*. 0)entually, that eetin" installed respondent Manuel $. Ro3as <<
as the new LP president. $tien'a et al :uestioned the e3istence of a :uoru and claied
that the 20(* coposition ou"ht to ha)e been based on a list appearin" in the partys -,
th
$nni)ersary =ou)enir Pro"ra. 7hey also coplained that $tien'a, the incubent party
chairan, was not in)ited to the 20(* eetin" and that soe ebers were "i)en the
status of 8"uests9 durin" the eetin". Ro3as, et al. claied that Ro3as election as LP
president faithfully coplied with the pro)isions of the aended LP (onstitution. 7he partys
-,th $nni)ersary =ou)enir Pro"ra could not be used for deterinin" the 20(* ebers
because super)enin" e)ents chan"ed the bodys nuber and coposition. (*M0L0( issued
the assailed resolution denyin" petitioners $tien'a, et al.s petition. <t noted that the May
+,,5 elections necessarily chan"ed the coposition of the 20(*. Petitioners failed to pro)e
that the 20(*, which elected Ro3as as LP president, was not properly con)ened. $s for the
)alidity of petitioners $tien'a, et al.s e3pulsion as LP ebers, the (*M0L0( obser)ed that
this was a ebership issue that related to disciplinary action within the political party. 7he
(*M0L0( treated it as an internal party atter that was beyond its 6urisdiction.
<==@0=A
B. CD2 the (*M0L0( "ra)ely abused its discretion when it upheld the 20(* ebership
that elected respondent Ro3as as LP president>
+. CD2 the (*M0L0( "ra)ely abused its discretion when it resol)ed the issue concernin" the
)alidity of the 20(* eetin" without /rst resol)in" the issue concernin" the e3pulsion of
$tien'a, et al. fro the party.
R@L<2!A
B. 2o. 7he 20(* was )alidly con)ened in accordance with the aended LP (onstitution.
Respondents Ro3as, et al. e3plained in details how they arri)ed at the 20(* coposition for
the purpose of electin" the party leaders.EB+F 7he e3planation is lo"ical and consistent with
party rules. (onse:uently, the (*M0L0( did not "ra)ely abuse its discretion when it upheld
the coposition of the 20(* that elected Ro3as as LP president.
+. 2o. 7he (*M0L0(s 6urisdiction o)er intra#party disputes is liited. Political parties are
"enerally free to conduct their acti)ities without interference fro the state. 7he (*M0L0(
ay inter)ene only when necessary to the dischar"e of its functions. (*M0L0( did not
"ra)ely abuse its discretion when it upheld Ro3as election as LP president but refused to
rule on the )alidity of $tien'a, et als e3pulsion fro the party. 7he :uestion of party
leadership has iplications on the (*M0L0(s perforance of its functions, but the sae
cannot be said of the issue pertainin" to $tien'a, et als e3pulsion fro the LP. =uch
e3pulsion is an issue of party ebership and discipline, in which the (*M0L0( cannot
inter)ene.