Case Digest (G.R. No. 86649)
Facts:
Anna Dominique M.L. Coseteng and Kababaihan Para sa Inang Bayan v. Hon. Ramon V. Mitra, Jr., et al., G.R. No. 86649, July 12, 1990, the Supreme Court En Banc, Grino‑Aquino, J., writing for the Court. The petitioners were Anna Dominique M.L. Coseteng (a lone congresswoman elected under the banner of Kababaihan Para sa Inang Bayan or KAIBA) and her party KAIBA; the respondents were the House leadership (Speaker Ramon V. Mitra, Jr., Majority Floor Leader Francisco Sumulong), the ex‑officio chairman of the Commission on Appointments (Jovito Salonga), and the House members elected to the Commission on Appointments (a list of twelve named members).After the May 11, 1987 congressional elections the House comprised members from various parties and coalitions, with petitioner Coseteng the sole KAIBA congresswoman. On August 26, 1987 the House initially elected eleven of its members to sit in the Commission on Appointments (COA), and on September 22, 1987 it elected Roque Ablan, Jr. as the twelfth member representing the minority. On September 16, 1988 the Laban ng Demokratikong Pilipino (LDP) organized and, as 158 of 202 House members formally affiliated with the LDP, the House undertook a reorganization of committees and its COA membership to reflect the new alignments.
Petitioner Coseteng wrote Speaker Mitra on October 8, 1988 requesting appointment to the COA and secured nine endorsements from other congressmen. On December 5, 1988 the House, upon motion of the Majority Floor Leader and over objection, revised its COA membership to reflect the new LDP majority by replacing Rep. Raul A. Daza with Rep. Luis C. Singson and listing ten LDP representatives, one LP representative (Lorna L. Verano‑Yap), and retaining Roque Ablan (KBL) for the minority seat.
On February 1, 1989 Coseteng and KAIBA filed a petition for extraordinary writs (characterized in the record as a petition for quo warranto and injunction) in the Supreme Court seeking to nullify the election of the named respondents to the COA, to enjoin them from acting as members, and to enjoin the House respondents from recognizing them. Petitioner contended the reorganization violated Section 18, Article VI of the 1987 Constitution because: (1) the new majority was entitled to only nine of the twelve House seats in the COA (not the number chosen); (2) members must be nominated by their respective political parties or coalitions; (3) the election of Verano‑Yap as minority representative was invalid; and (4) Ablan’s retention as the minority member was invalid because he was not nominated or elected by the minority.
The House respondents collectively argued the matter either presented a nonjusticiable political question or, alternatively, that the reorganization conformed to Section 18 because proportional representation could be computed with the Coalesced Majority treated as a form of a political party; they reported that by March 3, 1989 some 160 members had affiliated with the LDP and that the LDP’s registration was later granted by COMELEC (Aug. 28, 1989) and affirmed en banc (Nov. 23, 1989)....(Subscriber-Only)
Issues:
- Is the challenge to the House’s reorganization of its membership in the Commission on Appointments a nonjusticiable political question?
- Was the election of the twelve House members to the Commission on Appointments in December 1988/January 1989 conducted in violation of Section 18, Article VI of the 1987 Constitution (i.e., was proportional representation respected and was petitioner Coseteng entitled to a seat)?
- Must members of the House who sit in the Commission on Appointments be nominated by their respective political partie...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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