Facts:

The case centers around two petitions, filed by Ang Bagong Bayani - OFW Labor Party (represented by its Secretary-General, Mohammad Omar Fajardo) and Bayan Muna, against various respondents, including the Commission on Elections (COMELEC) and several political parties and organizations that participated in the party-list elections held on May 14, 2001. The petitions were filed with the Supreme Court of the Philippines under G.R. No. 147589 and G.R. No. 147613, respectively, culminating in a ruling dated June 25, 2003. The crux of the complaints was to question the proclamations of party-list winners amidst complexities surrounding the qualifications of various participants in the elections.

In the lower courts, specifically in a series of resolutions starting from June 26, 2001, the Supreme Court had directed the COMELEC to conduct summary evidentiary hearings on the qualifications of party-list participants in line with a set of guidelines. The hearings were crucial given the

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Facts:

Background of the Party-List System and Election Framework

• The case arises from the May 14, 2001 party-list elections where numerous groups vied for representation under a system characterized by unique parameters, such as a two-percent vote threshold for qualification and a three-seat limit per qualified party.
• The Philippine party-list law (RA 7941) and its policy declaration on proportional representation for marginalized and under-represented sectors form the statutory basis for the proceedings.

Compliance Reports and Determinations by COMELEC

• The Commission on Elections (COMELEC) issued a series of compliance reports—First, Second, and Final Partial Compliance Reports—to determine which party-list organizations met the eight-point guidelines set by the Court in its June 26, 2001 Decision.
• The reports recommended the qualification of certain groups (e.g., BAYAN MUNA, AKBAYAN!, BUTIL, APEC, CIBAC) and, initially, the disqualification of others on grounds such as failing to meet the required guidelines or being related to other organizations (e.g., BUHAY alleged to be an extension of El Shaddai and COCOFED considered an adjunct of the government).

Motions for Proclamation and Issues Raised

• Various party-list participants filed motions for proclamation as winners, questioning whether, aside from those already declared, other candidates should be proclaimed based on the statutory vote threshold.
• The petitioners raised the issue that votes cast for disqualified candidates should be excluded from the “total votes cast for the party-list system,” thereby lowering the base figure against which the two-percent threshold is measured.

Reconsideration and Subsequent Developments

• The Office of the Solicitor General (OSG) argued that the findings against BUHAY and COCOFED were not supported by substantial evidence, leading the Court to revisit these disqualifications.
• The Court, acting on submissions and consolidated replies, eventually accepted the OSG’s position and requalified BUHAY and COCOFED as meeting the stipulated guidelines.

Computation of Valid Votes and Determination of Winners

• The Court resolved that the votes obtained by disqualified candidates must be deducted from the overall total, reducing the base to 6,523,185 valid votes cast.
• Using this revised total, the Court applied Section 11(b) of RA 7941 to determine that only those parties garnering at least two percent of the valid votes qualify for a seat—resulting in the qualification of winners such as BAYAN MUNA, APEC, AKBAYAN!, BUTIL, CIBAC, BUHAY, AMIN, ABA, COCOFED, PM, SANLAKAS, and ABANSE! PINAY.
• A detailed computation using the formula from Veterans v. Comelec was utilized to further determine the additional seats (if any) to which the winning parties, especially the highest-performing group BAYAN MUNA, were entitled.

Issue:

Inclusion of Disqualified Votes in the Total Vote Count

• Whether the votes cast for party-list candidates that were later disqualified should be deducted from the “total votes cast for the party-list system” when computing the two-percent threshold.

Validity of the Disqualification of Certain Party-List Groups

• Whether groups such as BUHAY and COCOFED, originally disqualified on grounds of being linked to sectarian or governmental entities, should be requalified based on evidence of compliance with the guidelines.

Applicability of Precedents from Labo and Grego

• Whether the doctrines and interpretations from Labo v. Comelec and Grego v. Comelec—dealt with in the context of single elective posts—are applicable to the party-list system that is governed by distinct statutory provisions in RA 7941.

Methodology for Seat Allocation

• How to correctly calculate both the qualification (meeting the two-percent threshold) and the additional seats for the winning parties by applying the formulas derived in Veterans v. Comelec.
• The integrity of the party-list allocation formula in ensuring proportional representation in line with the objectives of the party-list system.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)