Facts
P3PWD Party-List, whose second-to-fifth nominees had already been substituted before COMELEC's November 15, 2021 deadline, won a House seat in the May 9, 2022 elections and its first nominee, Grace Yeneza, was proclaimed and took her oath. Before the congressional term began, all five nominees resigned in succession between June 7 and June 10, 2022. On June 14, 2022, P3PWD submitted an entirely new set of five substitute nominees led by former COMELEC Commissioner Ma. Rowena Amelia V. Guanzon. The COMELEC En Banc approved the substitution the very next day, subject only to later compliance with publication, and after denying Duterte Youth Party-List's opposition, proclaimed Guanzon, who took her oath. Duterte Youth filed a certiorari petition before this Court, which issued a TRO, and separately sought to hold Guanzon in indirect contempt for her public statements and conduct.
Issue
Whether the COMELEC committed grave abuse of discretion in approving, one day after filing, the post-election but pre-term wholesale substitution of a winning party-list's nominees.
Ruling
Yes. Section 8 of Republic Act No. 7941 allows substitution only upon a nominee's death, incapacity, or written withdrawal, and COMELEC Resolution No. 9366, as amended, validly fixed deadlines for these — November 15, 2021 for withdrawal-based substitution and midday of election day for death or incapacity — without supplanting the statute, since the deadlines carry out the electorate's right to know a party-list's nominees recognized in Lokin v. COMELEC, COCOFED v. COMELEC, and Bantay Republic Act v. COMELEC. Because the substitution predated noon of June 30, 2022, when the seat legally came into existence, Section 16's vacancy-filling rule did not yet apply, and the "directory after elections" doctrine of Engle v. COMELEC governs only matters of form, not nominee identity. The COMELEC's same-day approval, made without awaiting publication and over a commissioner's written objection, was "capricious and whimsical" grave abuse of discretion. The Court voided Minute Resolution No. 22-0774 insofar as it approved the substitution, made the TRO permanent, directed P3PWD to submit additional nominees under Section 16, but permanently barred it from renominating Guanzon and her four co-nominees for the Nineteenth Congress; the related contempt charges against Guanzon were dismissed.