G.R. No. 83216 - Quintos-Deles vs. Commission on Constitutional Commissions

On April 6, 1988, the President appointed four sectoral representatives pursuant to Article VII, Section 16, paragraph 2 and Article XVIII, Section 7 of the Constitution.
The nominees comprised Teresita Quintos-Deles for the Women’s Sector, Al Ignatius G. Lopez for the Youth Sector, Bartolome Arteche for the Peasants, and Rey Magno Teves for the Urban Poor.
Executive Secretary Catalino Macaraig, Jr. transmitted the appointments by letter to Speaker Ramon Mitra, Jr. on the same day, accompanied by copies of the respective appointment documents.

The newly appointed sectoral representatives were scheduled to take their oaths on April 18, 1988 at the Session Hall of Congress.
The oathtaking and commencement of duties were halted due to opposition from certain congressmen who were members of the Commission on Appointments (CA), who contended that the representatives must first secure confirmation.
Owing to this insistence for mandatory confirmation before oath-taking, Speaker Mitra suspended the oath-taking process.

On April 25, 1988, a letter dated April 11, 1988 from the President was transmitted to the Commission on Appointments, formally submitting the appointments for confirmation.
Prior to the scheduled confirmation meeting, petitioner Teresita Quintos-Deles sent a letter dated April 22, 1988 to Speaker Mitra, arguing that since previous sectoral appointments did not require a confirmation process, subjecting the current appointment to such process constituted discrimination.
In response, Speaker Mitra clarified by letter on May 2, 1988 that the President’s submission of the appointment to the CA meant that it fell within that body’s exclusive jurisdiction.

On May 10, 1988, petitioner Deles received an invitation to attend a CA committee meeting on May 12, 1988 for deliberating her appointment.
The petitioner replied on May 11, 1988, stating her position and questioning the CA’s jurisdiction over her appointment.
During the committee meeting chaired by Sen. Edgardo J. Angara, the CA ruled against the petitioner’s position.

The issue arose within the context of the party-list system and sectoral representation provisions of the 1987 Constitution.
Section 5 of Article VI provides for a House of Representatives composed of district representatives and party-list representatives, with one-half of the party-list seats reserved for sectoral representatives for specific sectors including women.
Section 7 of Article XVIII empowers the President to make appointments for sectoral representation until a law is passed providing otherwise.

Section 16 of Article VII enumerates the positions requiring the consent of the CA.
The Mison doctrine, as articulated in Sarmiento vs. Mison, clarifies that only appointments explicitly mentioned in the first sentence of Section 16 require CA confirmation.
Subsequent cases, including Mary Concepcion Bautista vs. Sen. Jovito Salonga, reaffirmed that appointments not falling within those enumerated positions must be made without CA participation.

Several intervening parties, including various petitioners and the Civil Liberties Union, filed memoranda in the case.
The Solicitor General, through his statement of position, supported the view that petitioner Deles’ appointment necessarily required confirmation by the CA.

Whether the Constitution mandates that the appointment of sectoral representatives to the House of Representatives must be confirmed by the Commission on Appointments.

Does the constitutional provision under Article VII, Section 16, paragraph 2, when read alongside Article XVIII, Section 7, impose a confirmation requirement for sectoral appointments?
Is the petitioner's contention that previous sectoral representatives took oath without confirmation a sufficient basis for exempting her appointment from the CA process?

The interpretation of specific constitutional provisions regarding the President’s appointment power

How should the provisions regarding appointment during congressional recess (Section 16, paragraph 2) be understood in relation to the mandatory confirmation process?
What is the significance of the Mison doctrine and subsequent jurisprudence in clarifying the scope of appointments requiring CA consent?