Case Summary (G.R. No. 86344)
Improper Impleader and Procedural Posture
Although the House itself made the challenged decision, the Court found no insurmountable procedural barrier. It treated the petition as akin to quo warranto, focusing on the respondent’s right to occupy the seat. Technical objections to naming the respondent were excused in deference to the case’s constitutional importance.
Precedent: Cunanan v. Tan and Temporary Alliances
In Cunanan v. Tan (1963), this Court held invalid a reorganization of the Commission based on a temporary “Allied Majority” because the defections did not reflect permanent party realignment. A constitutional organ may not be subject to frequent reorganizations based on ephemeral alliances.
Distinguishing Temporary Factions from Permanent Realignments
Here, the Court found that the LDP’s formation and the formal resignation of twenty-four legislators from the Liberal Party constituted a permanent shift. The subsequent registration by the Commission on Elections on November 23, 1989, confirmed the LDP’s legal status. The petitioner’s argument that a newly registered party must “age” before claiming representation was rejected as inconsistent with constitutional text and precedent.
Authority of the House to Reflect Changes in Party Proportions
Article VI, Section 18 implicitly empowers each House to ensure that its Commission representation mirrors current party proportions. This authority extends beyond the initial organi
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Background and Facts
- After the May 11, 1987 congressional elections, the House of Representatives apportioned its twelve seats in the Commission on Appointments among political parties per Article VI, Section 18 of the 1987 Constitution.
- Petitioner Rep. Raul A. Daza was elected as one of the twelve House representatives, designated to represent the Liberal Party.
- On September 16, 1988, the Laban ng Demokratikong Pilipino (LDP) was reorganized; twenty-four Liberal Party members formally resigned and joined the LDP, reducing the Liberal Party from 41 to 17 members and increasing LDP to 159 members.
- The House then revised its Commission on Appointments representation, withdrawing Daza’s seat and allocating it to the LDP. On December 5, 1988, Rep. Luis C. Singson was elected to fill this vacancy.
- Daza filed a petition on January 13, 1989, for prohibition and injunction challenging his removal and Singson’s assumption of the seat. A temporary restraining order was issued the same day.
Issues Presented
- Whether the House of Representatives validly removed petitioner from the Commission on Appointments based on a changed party alignment.
- Whether the reorganization was permanent and constitutionally permissible under Article VI, Section 18.
- Whether the petition raises a justiciable legal question or a nonjusticiable political question.
- Whether the LDP, not yet registered at the time of reorganization, could claim proportional representation.
- Whether Luis C. Singson was improperly impleaded as respondent.
Arguments of the Parties
- Petitioner’s Contentions:
- His seat in the Commission on Appointments is permanent under the doctrine of Cunanan v. Tan.
- The LDP is not a duly registered political party and lacks the permanence required for reallocating seats.
- Respondent’s Contentions (Singson):
- The question is political in nature and beyond the Court’s jurisdiction.
- He was improperly impleaded; the proper respondent is the House of Representatives.
- Registration of a party is not a constitutional requirement for proportional representation.
- Amicus Curiae (Solicitor General):
- Submitted a Comment supporting resolution of the constitutional issues.
Jurisdictional Ruling
- The Court held that it has jurisdiction to review the legality, not the wisdom, o