ATIENZA VS COMELEC G.R. No.

188920 FACTS: The case is a 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. On July , !"" respondent #ran$lin %. &rilon '&rilon(, as erstwhile president of the )iberal *arty ')*(, announced his party+s withdrawal of support for the administration of *resident ,loria %acapagal-.rroyo. /ut petitioner Jose ). .tien0a, Jr. '.tien0a(, )* Chairman, and a number of party members denounced &rilon+s move, claiming that he made the announcement without consulting his party. On %arch !, !""1 petitioner .tien0a hosted a party conference to supposedly discuss local autonomy and party matters but, when convened, the assembly proceeded to declare all positions in the )*+s ruling body vacant and elected new officers, with .tien0a as )* president. 2espondent &rilon immediately filed a petition with the Commission on 3lections 'CO%3)3C( to nullify the elections. 4e claimed that it was illegal considering that the party+s electing bodies, the 5ational 3xecutive Council '53CO( and the 5ational *olitical Council '5.*O)CO(, were not properly convened. &rilon also claimed that under the amended )* Constitution, party officers were elected to a fixed three-year term that was yet to end on 5ovember 6", !""7. The CO%3)3C held that the election of .tien0a and others was invalid since the electing assembly did not convene in accordance with the )* Constitution. %oreover, the CO%3)3C ruled that since the said Constitution was not ratified, &rilon was only sitting in a hold-over capacity since his term has been ended already. 8ubsequently, the )* held a 53CO meeting to elect new party leaders before respondent &rilon+s term expired which resulted to the election of 2oxas as the new )* president. .tien0a et al. sought to en9oin 2oxas from assuming the presidency of the )* questioning the validity of the quorum. The CO%3)3C issued resolution denying petitioners .tien0a et al.+s petition. .s for the validity of petitioners .tien0a, et al.+s expulsion as )* members, the CO%3)3C observed that this was a membership issue that related to disciplinary action within the political party. The CO%3)3C treated it as an internal party matter that was beyond its 9urisdiction to resolve. ISSUE: :hether or not the CO%3)3C has 9urisdiction over intra-party dispute

HELD: The CO%3)3C+s 9urisdiction over intra-party disputes is limited. It does not have blan$et authority to resolve any and all controversies involving political parties. *olitical parties are generally free to conduct their activities without interference from the state. The CO%3)3C may intervene in disputes internal to a party only when necessary to the discharge of its constitutional functions. The Court ruled in Kalaw v. Commission on Elections that the CO%3)3C+s powers and functions under 8ection !, .rticle I;-C of the Constitution, <include the ascertainment of the identity of the political party and its legitimate officers responsible for its acts.= %oreover, the CO%3)3C+s power to register political parties necessarily involved the determination of the persons who must act on its behalf. Thus, the CO%3)3C may resolve an intra-party leadership dispute, in a proper case brought before it, as an incident of its power to register political parties. The CO%3)3C did not err when it upheld 2oxas+ election but refused to rule on the validity of .tien0a+s expulsion.