Akbayan Youth v. Comelec.c6docx

AKBAYAN – YOUTH v.
COMELEC
March 26, 2001 | Buena, J. | Statute construed as a whole
PETITIONER: AKBAYAN – Youth et al.

RESPONDENTS: Commission on Elections
SUMMARY: Petitioners in this case represent the youth sector and they seek to seek to direct COMELEC to conduct a special
registration before the May 14, 2001 General Elections, of new voters ages 18 to 21. According to them, around four million youth
failed to register on or before the December 27, 2000 deadline set by the respondent COMELEC. However, the COMELEC issued
Resolution No. 3584 disapproving the request for additional registration of voters on the ground that Section 8 of R.A. 8189 explicitly
provides that no registration shall be conducted during the period starting one hundred twenty (120) days before a regular election and
that the Commission has no more time left to accomplish all pre-election activities. Aggrieved by the denial, petitioners filed before
the SC the instant case which seeks to set aside and nullify respondent COMELEC’s Resolution and/or to declare Section 8 of R. A.
8189 unconstitutional insofar as said provision effectively causes the disenfranchisement of petitioners and others similarly situated.
Likewise, petitioners pray for the issuance of a writ of mandamus directing respondent COMELEC to conduct a special registration of
new voters and to admit for registration petitioners and other similarly situated young Filipinos to qualify them to vote in the May 14,
2001 General Elections. The Court held that the right of suffrage invoked by the petitioners is not absolute.
DOCTRINE: Similarly, every new statute should be construed in connection with those already existing in relation to the same
subject matter and all should be made to harmonize and stand together, if they can be done by any fair and reasonable interpretation.
Interpretare et concordare legibus est optimus interpretandi, which means that the best method of interpretation is that which
makes laws consistent with other laws. Accordingly, courts of justice, when confronted with apparently conflicting statutes, should
endeavor to reconcile them instead of declaring outright the invalidity of one against the other. Courts should harmonize them, if this
is possible, because they are equally the handiwork of the same legislature.
ISSUE/s:
1. Whether COMELEC committed grave abuse of disecretion in issuing the assailed resolution – NO
RULING: WHEREFORE, premises considered, the instant petitions for certiorari and mandamus are hereby DENIED. SO
ORDERED.
RATIO:
1. The Court held that Section 8 of R.A. 8189 applies in the present case, for the purpose of upholding the assailed COMELEC
Resolution and denying the instant petitions, considering that the aforesaid law explicitly provides that no registration shall
be conducted during the period starting one hundred twenty (120) days before a regular election.
2. It bears emphasis that the provisions of Section 29 of R.A. 8436 invoked by herein petitioners and Section 8 of R.A. 8189
volunteered by respondent COMELEC, far from contradicting each other, actually share some common ground. True
enough, both provisions, although at first glance may seem to be at war in relation to the other, are in a more circumspect
perusal, necessarily capable of being harmonized and reconciled. Below are the specific provisions.
Section 29, Republic Act No. 6646 and adopted verbatim in Section 28 of Republic Act No. 8436:
SEC. 28. Designation of other Dates for Certain Pre-election Acts - Ifit should no longer bepossible to observe the
periods and dates prescribed by law for certain pre-election acts, the Commission shall fix other periods and dates
in order to ensure accomplishments of the activities so voters shall not be deprived of their right to suffrage.
Section 8, Republic Act No. 8189:
SEC. 8. System of Continuing Registration of Voters. The Personal filing of application of registration of voters
shall be conducted daily in the office of the Election Officer during regular office hours. No registration shall,
however, be conducted during the period starting one hundred twenty (120) days before a regular election and
ninety (90) days before a special election.
3. Rudimentary is the principle in legal hermeneutics that changes made by the legislature in the form of amendments to a
statute should be given effect, together with other parts of the amended act. It is not to be presumed that the legislature, in
making such changes, was indulging in mere semantic exercise. There must be some purpose in making them, which should
be ascertained and given effect.
4. Similarly, every new statute should be construed in connection with those already existing in relation to the same subject
matter and all should be made to harmonize and stand together, if they can be done by any fair and reasonable interpretation.
10 Interpretare et concordare legibus est optimus interpretandi, which means that the best method of interpretation is that
which makes laws consistent with other laws. Accordingly, courts of justice, when confronted with apparently conflicting
statutes, should endeavor to reconcile them instead of declaring outright the invalidity of one against the other. Courts should
harmonize them, if this is possible, because they are equally the handiwork of the same legislature.

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AKBAYAN – YOUTH v.

PETITIONER: AKBAYAN – Youth et al.

Section 8, Republic Act No. 8189:

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