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

Case Summary (G.R. No. 86344)

Factual Background

After the May 11, 1987 congressional elections, the House of Representatives apportioned its twelve seats in the Commission on Appointments on the basis of proportional representation among the parties then represented in the chamber. Rep. Raul A. Daza was chosen and listed as a representative of the Liberal Party. On September 16, 1988, the Laban ng Demokratikong Pilipino (LDP) was reorganized, and twenty-four members of the Liberal Party formally resigned and joined the LDP, increasing that party's House strength and reducing the Liberal Party to seventeen members. The House then revised its representation in the Commission on Appointments to reflect the new alignments, withdrawing the seat held by the petitioner and awarding it to the LDP, and on December 5, 1988 elected a new set of representatives that excluded the petitioner and included Rep. Luis C. Singson as the additional LDP member.

Procedural History

On January 13, 1989, the petitioner filed a petition with this Court seeking prohibition and injunction to prevent his removal from the Commission on Appointments and to restrain the respondent from assuming the contested seat. The Court issued a temporary restraining order the same day, preventing both the petitioner and the respondent from serving in the Commission on Appointments. The Solicitor General submitted a Comment as amicus curiae. The Court resolved the matter by a decision promulgated December 21, 1989.

Issues Presented

The principal questions were whether the House of Representatives lawfully changed its delegation to the Commission on Appointments to reflect the newly formed LDP, whether such change was justiciable or a nonjusticiable political question, and whether the petitioner could claim permanent tenure on the Commission under the doctrine of Cunanan v. Tan. A subsidiary issue was whether a political party must be duly registered to be entitled to proportional representation in the Commission on Appointments.

Parties' Contentions

The petitioner maintained that his election to the Commission on Appointments was permanent under Cunanan v. Tan, and that the reorganization was invalid because the LDP was not a duly registered party and had not attained political stability. The petitioner argued that the LDP's nonregistration precluded it from being considered for proportional representation. The respondent contended that the dispute presented a political question beyond judicial review, that he was improperly impleaded because the House, not he, changed the representation, and that the Constitution does not require party registration to determine proportional representation. The Solicitor General supported the respondent's position on the substance of the change.

Jurisdictional Analysis

The Court held that the dispute was justiciable because it involved the legality, not the wisdom, of the House's action in changing its Commission on Appointments delegation. The Court relied on the principle articulated in Tanada v. Cuenco that the label "political question" covers matters of policy or wisdom assigned to political branches, whereas courts may review exercises of power that are subject to constitutional limitations. The Court further observed that even if the issue implicated political questions, the Judiciary's expanded jurisdiction under the Constitution included authority to determine whether a grave abuse of discretion had occurred, citing the constitutional provision as quoted in the record. The Court also rejected the objection of improper impleader as a bar to relief, noting that the petition could be treated as one for quo warranto or otherwise entertained in view of the matter's constitutional importance.

Review of Cunanan v. Tan

The Court reviewed Cunanan v. Tan as the principal precedent invoked by both parties. In Cunanan, the Court had held that a reorganization of a House delegation to the Commission on Appointments was invalid when it resulted from a merely temporary combination of members who had not permanently disaffiliated from their original party. The Court in Cunanan emphasized that shifting votes or ephemeral alliances did not authorize repeated reorganizations that would place a constitutional body at the mercy of transient House coalitions. The petitioner relied on that decision to argue that the LDP realignment was similarly transient; the respondent relied on it to argue that permanent shifts allow reorganization.

Subsequent Development on Party Registration

An intervening administrative development materially affected the petitioner's argument. On November 23, 1989, the Commission on Elections, en banc, affirmed a prior resolution granting the LDP registration as a political party (SPP No. 88-001, SPC No. 88-839). That registration removed the ground that the LDP was ineligible to be considered in apportioning representation. The Court held that the petitioner's alternative contention — that a party must pass the test of time even if registered — was untenable. The Court noted historical practice where newly formed parties had been represent

Case Syllabus (G.R. No. 86344)

Parties and Posture

REP. RAUL A. DAZA filed a petition challenging his removal from the Commission on Appointments and the seating of REP. LUIS C. SINGSON therein.
HON. RAOUL V. VICTORINO was impleaded in his capacity as Secretary of the Commission on Appointments.
The petition was filed on January 13, 1989, and a temporary restraining order was issued the same day enjoining both the petitioner and the respondent from serving.
The Solicitor General submitted a Comment as amicus curiae in compliance with the Court's order.
Justice Sarmiento took no part in the decision by reason of his role as Secretary General of the Liberal Party.

Key Facts

After the May 11, 1987 congressional elections, the House apportioned its 12 seats in the Commission on Appointments among political parties on a proportional basis.
The petitioner was initially chosen and listed as a representative of the Liberal Party.
On September 16, 1988, the Laban ng Demokratikong Pilipino (LDP) was reorganized and 24 members of the Liberal Party joined the LDP, reducing the Liberal Party to 17 members.
The House revised its Commission on Appointments representation, withdrew the seat held by the petitioner, and on December 5, 1988 elected a new set of representatives that included REP. LUIS C. SINGSON as an additional LDP member.
The petitioner contended that his election to the Commission was permanent under Cunanan v. Tan and that the LDP lacked permanence and registration.

Constitutional Provision

The Court anchored its analysis on Article VI, Section 18, of the Constitution, which prescribes a Commission on Appointments consisting of the President of the Senate, 12 Senators, and 12 House members elected by each House on the basis of proportional representation of political parties and parties or organizations registered under the party-list system represented therein.
The Court also invoked provisions concerning judicial power and review found in the Constitution as cited in the decision, including the provisions quoted as Article VII, Section 1, of the Constitution and later as Article VIII, Section 1, of the Constitution in support of judicial review for grave abuse of discretion.

Issues Presented

Whether the House of Representatives may validly change its representation in the Commission on Appointments to reflect changed political alignments.
Whether the reorganization that removed the petitioner was justiciable or constituted a nonreviewable political question.
Whether a newly formed and unregistered political party may be considered for proportional representation in the Commission on Appointments.
Whether the respondent was properly impleaded and entitled to sit as a member of the Commission on Appointments.

Parties' Contentions

The petitioner argued that his position in the Commission on Appointments was permanent under Cunanan v. Tan and that the LDP was not a duly registered or permanent party to justify reorganization.
The respondent maint