Case Digest (G.R. No. 246816)
Facts:
The case involves the petitioners Angkla: Ang Partido ng mga Marinong Pilipino, Inc. (ANGKLA) and Serbisyo sa Bayan Party (SBP), along with the petitioner-in-intervention Aksyon Magsasaka - Partido Tinig ng Masa (AKMA-PTM), who filed twin petitions for certiorari and prohibition against the Commission on Elections (COMELEC) and its officials. The petitions were filed on September 15, 2020, following the May 13, 2019 party-list elections in the Philippines. The petitioners challenged the constitutionality of Section 11(b) of Republic Act No. 7941, which stipulates that parties receiving at least two percent (2%) of the total votes cast for the party-list system are entitled to one guaranteed seat each, and those garnering more than two percent (2%) are entitled to additional seats in proportion to their total number of votes. The petitioners argued that this provision results in the double-counting of votes, violating the equal protection clause of the Constitution. They sough...
Case Digest (G.R. No. 246816)
Facts:
Parties Involved:
- Petitioners: ANGKLA: Ang Partido Ng Mga Pilipinong Marino, Inc. (ANGKLA), Serbisyo sa Bayan Party (SBP), and Aksyon Magsasaka-Partido Tinig ng Masa (AKMA-PTM).
- Respondents: Commission on Elections (COMELEC), sitting as the National Board of Canvassers, and its commissioners.
Legal Provision Challenged:
- Section 11(b) of Republic Act No. 7941 (Party-List System Act), which provides that party-lists garnering more than 2% of the votes cast for the party-list system are entitled to additional seats in proportion to their total number of votes.
Petitioners' Argument:
- The allocation of additional seats based on the "total number of votes" results in double-counting of votes in favor of party-lists that already secured a seat by meeting the 2% threshold.
- This violates the equal protection clause of the Constitution.
- Petitioners propose a framework where votes amounting to 2% are deducted from the total votes of party-lists that secured a guaranteed seat before allocating additional seats.
Background:
- The National Board of Canvassers (NBOC) promulgated NBOC Resolution No. 004-19, declaring the winning party-list groups in the May 13, 2019 elections.
- Petitioners amended their petition to seek the annulment of NBOC Resolution No. 004-19, arguing that it violated the Court's ruling in BANAT v. COMELEC.
- Petitioners also sought to be proclaimed as entitled to at least one seat each in the House of Representatives.
Intervenor's Argument:
- AKMA-PTM, as petitioner-in-intervention, echoed the main petitioners' arguments and provided a detailed computation to support their claim that the allocation of seats was flawed.
Respondent's Defense:
- The Office of the Solicitor General (OSG) defended COMELEC, arguing that there is no double-counting of votes. The first round of seat allocation ensures representation for party-lists with sufficient constituencies, while the second round ensures compliance with the constitutional mandate that 20% of the House of Representatives be elected via the party-list system.
Issue:
- Whether Section 11(b) of RA 7941, which allows party-lists garnering more than 2% of the votes to receive additional seats in proportion to their total number of votes, violates the equal protection clause.
- Whether the COMELEC's allocation of seats in the May 13, 2019 party-list elections, as outlined in NBOC Resolution No. 004-19, is unconstitutional.
- Whether the petitioners and petitioner-in-intervention are entitled to at least one seat each in the House of Representatives under their proposed framework.
Ruling:
The Supreme Court dismissed the petition for lack of merit. The Court upheld the constitutionality of Section 11(b) of RA 7941 and the COMELEC's allocation of seats in the May 13, 2019 party-list elections.
No Double-Counting of Votes:
- The Court ruled that there is no double-counting of votes. The first round of seat allocation ensures that party-lists with sufficient constituencies are represented, while the second round ensures compliance with the constitutional mandate of 20% party-list representation in the House of Representatives.
Equal Protection Clause Not Violated:
- The Court found that the distinction between party-lists that garner more than 2% of the votes and those that do not is based on a substantial distinction. Party-lists that garner more than 2% have a clearer mandate from the people, justifying the allocation of additional seats.
Prospective Application of Alternative Formula:
- The Court declined to apply the petitioners' proposed framework retroactively, as it would disrupt the current composition of the House of Representatives. Any discussion on alternative formulas for seat allocation should be applied prospectively.
Ratio:
- (Unlock)