G.R. No. 86344 - Daza vs. Singson

After the May 11, 1987 elections, the House of Representatives apportioned its 12 seats in the Commission on Appointments (COA) among parties in accordance with Article VI, Section 18 of the 1987 Constitution.
Representative Raul A. Daza was chosen as one of the Liberal Party’s appointees to the COA.

On September 16, 1988, the Laban ng Demokratikong Pilipino (LDP) was formed, with 24 members of the Liberal Party defecting to it, reducing the Liberal Party’s House membership from 41 to 17.
The House then withdrew Daza’s COA seat and, on December 5, 1988, elected Luis C. Singson as the additional LDP representative.

On January 13, 1989, Daza filed a petition for prohibition and injunction, challenging his removal and Singson’s assumption of office. The Supreme Court issued a temporary restraining order preventing either from serving.
Daza invoked Cunanan v. Tan to argue his COA seat was permanent and contended LDP was not yet a duly registered or stable party. Singson claimed the matter was a non‐justiciable political question and that no registration requirement existed for COA representation.

Article VI, Section 18, provides that the COA comprises 12 Senators and 12 House members elected on the basis of proportional representation of parties represented in each House.
The Solicitor General, as amicus curiae, submitted a comment supporting the validity of the House’s reorganization.

Is the Court competent to review the House’s act of removing Daza from the COA, or is it a non‐justiciable political question?
Does the expanded jurisdiction under Article VIII, Section 1, permit review of such alleged grave abuse of discretion?

Does the formation and membership shift to the LDP constitute a “permanent” realignment justifying COA reorganization?
Must a political party be registered with the Commission on Elections to qualify for proportional representation in the COA?