Case Digest (G.R. No. 246816) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Angkla: Ang Partido ng mga Pilipinong Marino, Inc. (ANGKLA) and Serbisyo sa Bayan Party (SBP), joined by intervenor Aksyon Magsasaka–Partido Tinig ng Masa (AKMA-PTM), filed an amended petition against the Commission on Elections (COMELEC) sitting en banc as the National Board of Canvassers. On May 22, 2019, the NBOC issued Resolution No. 004-19 proclaiming the winners in the May 13, 2019 party-list elections. Pursuant to Republic Act No. 7941, Section 11(b), COMELEC employed a two-round scheme: the first round granted one guaranteed seat each to parties securing at least two percent of all party-list votes; the second round awarded additional seats “in proportion to their total number of votes,” subject to a three-seat cap. Petitioners claim that using the same votes in both rounds results in “double counting” favoring the two-percenters, thus breaching the Equal Protection Clause of the 1987 Constitution. They urge the Court to enjoin double counting by first deducting the two-... Case Digest (G.R. No. 246816) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Nature of the Case
- Angkla: Ang Partido ng mga Pilipinong Marino, Inc. (ANGKLA) and Serbisyo sa Bayan Party (SBP) filed a petition for certiorari and prohibition against the Commission on Elections (COMELEC), sitting as the National Board of Canvassers (NBOC), claiming grave abuse of discretion in the allocation of party-list seats.
- Aksyon Magsasaka-Partido Tinig ng Masa (AKMA-PTM) intervened, adopting the same arguments.
- Statutory and Constitutional Framework
- Article VI, Section 5(2) of the 1987 Constitution reserves 20% of the House membership for party-list representatives.
- Republic Act No. 7941, Section 11(b) provides:
- Parties garnering at least 2% of party-list votes get one guaranteed seat each.
- Those garnering more than 2% are entitled to additional seats “in proportion to their total number of votes,” with a 3-seat cap.
- 2019 Party-List Election and Canvass
- NBOC Resolution No. 004-19 (22 May 2019) allocated 61 party-list seats among 51 groups, including:
- Eight “two-percenters” (each guaranteed one seat and awarded additional seats per the BANAT formula).
- Forty-three non-two-percenters (each awarded one seat in the second round).
- Petitioners ANGKLA, SBP, and intervenor AKMA-PTM were ranked 52nd to 54th and received no seats.
- Petitioners’ Theory of Relief
- They claim Section 11(b)’s proviso results in “double-counting” of the same votes—first to secure the guaranteed seat and again in distributing additional seats—thus violating the equal protection clause and “one vote, one weight.”
- They propose a modified formula:
- Deduct the 2% votes already used for a guaranteed seat before distributing additional seats.
- Re-rank and distribute remaining seats proportionally to the recomputed votes.
- Respondents’ Defense
- The COMELEC and the Office of the Solicitor General (OSG) invoke BANAT v. COMELEC, asserting no double-counting because the two rounds serve distinct purposes (threshold vs. filling-up 20% membership).
- They maintain the proviso and BANAT formula are constitutional, reflecting Congress’s discretion to balance proportionality, threshold, and a 3-seat cap.
Issues:
- Does Section 11(b) of RA 7941, in providing that parties garnering more than 2% of party-list votes are entitled to additional seats “in proportion to their total number of votes,” violate the equal protection clause by “double-counting” votes?
- Did the COMELEC commit grave abuse of discretion in NBOC Resolution No. 004-19 by applying the BANAT formula to allocate party-list seats?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)