Case Summary (G.R. No. 179271)
Applicable Laws and Constitutional Provisions
The case is governed by the 1987 Philippine Constitution, specifically Article VI, Section 5, which provides that the House of Representatives shall consist of no more than 250 members, with a party-list system contributing to this membership. Additionally, Republic Act No. 7941, known as the Party-List System Act, outlines the framework for party-list representation, including various thresholds and caps related to seat allocation.
Key Issues and Clarifications Sought
The House of Representatives raised several concerns: the accuracy of the number of legislative districts, which they clarified should be 219 rather than 220, prompting questions about the correct number of party-list seats. Specifically, whether the total should be 54 seats as per the legislative districts or 55 as previously awarded by the Court. They sought guidance on whether to enroll 32 party-list representatives identified in the decision or to limit the number to fill the constitutional maximum of 250 members.
Constitutional Rulings on Party-List Seats
The Supreme Court declared that the 2% threshold specified in Section 11(b) of R.A. No. 7941 was unconstitutional for the distribution of additional party-list seats. The Court clarified that this threshold is no longer necessary for parties seeking to gain additional representation after the guaranteed seats have been allocated, thereby allowing for a more inclusive process that aligns with constitutional provisions that require proportional representation.
Discrepancies in Vote Counting and Seat Allocation
Following the Supreme Court's prior ruling in April 2009, the number of total votes and updated data from the Commission on Elections indicated that vote counts and rankings had changed post-decision. Specifically, the total number of votes cast for party-list representatives was adjusted to reflect 15,723,764 after the cancellation of a party-list group's registration, leading to different rankings compared to initial calculations presented.
Clarification of Party-List Capacity and Allocation Procedures
The Court underscored that the mechanism for party-list seat allocation involves routine adjustments in accordance with the number of legislative districts. The formula stated in Section 5(2) of the Constitution mandatorily allows for party-list representatives to make up 20% of the total representatives, reflecting changes due to the dynamics of legislative districts without requiring new legislation for every district increase.
Conclusion on Party-List Representation Dynamics
The ruling articulates that any allocation of party-list seats must not strictly adhere to previous thresholds, paving the way for a more flexible distribution mechanism tha
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Case Background
- The case involves multiple petitions concerning the party-list representatives elected during the 2007 elections.
- The petitioner, BANAT, filed against the Commission on Elections (COMELEC) along with several intervenors including Arts Business and Science Professionals, Aangat Tayo, and the Coalition of Associations of Senior Citizens in the Philippines, Inc.
- The House of Representatives, represented by Speaker Prospero C. Nograles, sought to intervene and clarify issues regarding the number of legislative districts and party-list representatives.
Issues Raised by the House of Representatives
- The House indicated that there are only 219 legislative districts, not 220, leading to a contention that only 54 seats should be allocated for party-list representation instead of 55.
- Clarification was sought on which party-list representatives should be included in the Roll of Members, particularly concerning the 32 named representatives and whether admitting all would violate the constitutional limit of 250 members.
- The House also questioned the interpretation of the term "additional seats," and whether this included all remaining seats or only 2nd and 3rd seats, especially after the court declared the 2% threshold unconstitutional for additional seat allocation.
Motions and Interventions
- Armi Jane Roa-Borje, the third nominee of Citizens' Battle Against Corruption (CIBAC), filed a motion for partial reconsideration, arguing that the ruling deprived parties with larger constituencies of representation in favor of those who did not mee