Case Digest (G.R. No. 86344)
Facts:
Rep. Raul A. Daza v. Rep. Luis C. Singson and Hon. Raoul V. Victorino, G.R. No. 86344, December 21, 1989, Supreme Court En Banc, Cruz, J., writing for the Court.After the May 11, 1987 congressional elections, the House of Representatives apportioned its twelve seats in the Commission on Appointments among parties represented in that chamber pursuant to Article VI, Section 18 of the Constitution; Raul A. Daza (petitioner) was chosen as one of the House representatives and listed as representing the Liberal Party. On September 16, 1988 the Laban ng Demokratikong Pilipino (LDP) was reorganized, and 24 members of the Liberal Party formally left to join the LDP, reducing the Liberal Party’s House membership substantially.
Relying on that realignment, the House revised its representation in the Commission on Appointments: it withdrew the seat held by petitioner and, on December 5, 1988, elected a new set of representatives that omitted Daza and included Luis C. Singson (respondent) as an additional LDP member. On January 13, 1989 Daza filed a petition before the Supreme Court challenging his removal and Singson’s assumption of the seat; the Court issued a temporary restraining order that same day enjoining both Daza and Singson from serving in the Commission pending resolution.
Petitioner chiefly relied on Cunanan v. Tan (5 SCRA 1) to argue that his election was effectively permanent and that the House could not reorganize the Commission on Appointments on the basis of a purportedly temporary shift; he also asserted that the LDP was not a duly registered or politically stable party entitled to proportional representation. Respondent contended the dispute was a nonjusticiable political question, argued improper impleading (the House was the true actor), and maintained that the Constitution does not require registration for entitlement to proportional representation. The Solicitor General filed a Comment as amicus curiae.
Substantively, the Court examined whether the controversy was justiciable, whether the impleading of Singson was fatal, and whether the House validly changed its representation in the Commission on Appointments in light of Cunanan v. Tan and the alleged non-registration or impermanence of the LDP. Subsequent to the filing, the Commission on Elections (COMELEC), in SPP No. 88-001 (SPC...(Subscriber-Only)
Issues:
- Is the controversy a nonjusticiable political question or is it justiciable by the Court?
- Can respondent Singson be properly impleaded and subject to this proceeding despite the House being the actor that changed representation?
- Was the House of Representatives’ reorganization of its Commission on Appointments representation valid so as to remove petitioner Daza and entitle respondent Singson to the seat — specifically, did the LDP’s formation and status supply the “permanent” change required by Cun...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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