Case Summary (G.R. No. 106971)
Applicable Law and Constitutional Basis
The case is decided under the 1987 Philippine Constitution, particularly Article VI, Section 18, which governs the composition of the Commission on Appointments. It mandates that the CA consist of the President of the Senate as ex-officio Chairman, twelve senators, and members of the House of Representatives, all elected on the basis of proportional representation of political parties.
Grounds of the Motions for Reconsideration
Respondents filed separate motions for reconsideration challenging the Supreme Court's October 20, 1992 decision. Senator Tanada argued:
- Erroneous appreciation of factual precedents;
- The decision ignored the multi-party system recognized by the Constitution;
- Mandatory nature of filling all twelve seats in the Commission; and
- Absence of grave abuse of discretion in his election to the CA.
Senators Gonzales and Romulo contended:
- Inconsistency of the decision with Supreme Court rulings in Coseteng vs. Mitra and Daza vs. Singson;
- Mandatory nature of electing twelve CA members for its functionality;
- Validity of the Tolentino Compromise Formula governing the selection of senators to the CA; and
- Compliance of their election with the multi-party system and party realignment to avoid fractional membership.
Supreme Court's Denial of the Motions: Interpretation of Article VI, Section 18
The Court upheld its earlier decision, emphasizing the clear constitutional directive for proportional representation of political parties in the CA membership. The numerical strength of parties in the Senate was undisputed as follows: LDP - 7.5, LP-PDP-LABAN - 0.5, NPC - 2.5, Lakas-NUCD - 1.5. The Court found that converting fractional memberships into whole memberships by combining halves to favor a majority party violated the proportional representation mandate, as it diminished the rightful representation of minority parties. This action constituted a grave abuse of discretion as it undermined the constitutional balance intended by the framers to prevent domination by the majority party.
Historical Membership and Precedent on Proportional Representation
The Court clarified that the membership of the late Senator Lorenzo Tanada in the CA, cited by respondents as precedent, does not support overriding the constitutional rule on proportional representation. Senator Tanada's prior membership was a product of party coalitions rather than a constitutional entitlement based on fractional representation, and this membership was never constitutionally challenged or judicially affirmed as a precedent. The Court stressed that mere legislative practice, without judicial acquiescence, cannot establish precedents that contravene the Constitution.
Political Party Affiliations at the Time of Election
The Court recognized an erroneous reference in its earlier decision regarding Senator Guingona's party affiliation but noted that respondents accepted that actual political party membership at the time of CA election is the proper basis for determining proportional representation. This acceptance aligns with the Daza vs. Singson doctrine, which permits changing political alignments to affect membership, thus resolving this issue against respondents' arguments.
Nomination and Election Procedure in the Senate
It was clarified that Senator Tanada was nominated by the Liberal Party due to procedural rules requiring party nomination, and the motion for his election was presented by the Senate’s Majority Leader, Senator Romulo. The election of CA members must conform to partisan proportionality and cannot be manipulated by the majority party to include more than their share by combining fractional memberships.
Proportional Representation Requires Minimum Membership
The Court reaffirmed that proportional representation in the CA requires that political parties possess at least a minimum number of members in a house to be entitled to membership in the CA. The mere presence of a single senator does not guarantee a party a seat in the CA. This clarified the respondents’ misinterpretation of prior rulings, particularly Coseteng vs. Mitra, which was cited to negate automatic entitlement.
The Number of Commission Members is Maximum, Not Mandatory Full Complement
The Court held that the Constitution's specification of twelve senators in the CA is a maximum figure and not an absolute requirement that all slots be filled to validate the Commission’s functions. The Constitution prioritizes proportional representation over the full membership. The CA can convene and act with a quorum less than the full complement, in accordance with its own rules requiring at least thirteen members (from both houses), and can validly transact business with fewer than twelve senators elected as members.
Clarification on Coalition as a Practical Solution, Not Mandate
The Court clarified that its previous suggestion that political parties with fractional memberships form coalitions to complete full membership was merely a suggestion to break the impasse, not a constitutional requirement. The formation of coalitions should not result in
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Case Background and Procedural History
- The case emanates from motions for reconsideration filed separately by respondent Senators Wigberto Tanada, Neptali A. Gonzales, and Alberto Romulo contesting the Supreme Court's decision dated October 20, 1992.
- Senator Tanada's motion based his grounds on alleged erroneous factual precedents, neglect of the multi-party system, mandatory filling of twelve seats in the Commission on Appointments (CA), and claimed lack of grave abuse of discretion in his election to the CA.
- Senators Gonzales and Romulo's motion stressed inconsistency with prior Supreme Court rulings (Coseteng vs. Mitra Jr. and Daza vs. Singson), the mandatory nature of twelve-member CA to function constitutionally, adoption of the Tolentino Compromise Formula by the Senate, and alignment with the multi-party system to prevent fractional party memberships.
- The Nationalist People's Coalition (NPC) as petitioner-in-intervention and the original petitioners submitted comments opposing the motions.
- The Supreme Court ultimately denied the motions for reconsideration, affirming its original ruling.
Constitutional Provision and Interpretation: Article VI, Section 18 of the 1987 Constitution
- The decision is principally founded on a straightforward interpretation and application of Article VI, Section 18 of the 1987 Constitution.
- The section mandates that the Commission on Appointments consist of the Senate President as ex-officio Chairman and twelve Senators elected based on proportional representation of political parties represented in the Senate.
- The proportional representation rule requires that each political party’s membership in the CA reflect its respective share of Senate seats, including fractional memberships.
- The key constitutional command is strict adherence to the multi-party system and proportional representation, disallowing any party from acquiring greater representation than constitutionally entitled.
- Any practice of aggregating fractional party memberships (such as combining two halves into a whole for election purposes) violates Section 18 as it distorts proportional representation and unfairly diminishes minority party representation.
- The constitutional provision functions as a safeguard to prevent majoritarian domination through sheer numbers, protecting minority interests within the Commission.
Political Party Representation and Fractional Memberships in the Commission on Appointments
- Established party representation in the Senate at the pertinent time consisted of: LDP - 7.5, LP-PDP-LABAN - 0.5, NPC - 2.5, Lakas-NUCD - 1.5; all parties acknowledged entitlement to fractional memberships per proportional representation.
- The LDP majority effectively “converted” a 0.5 fraction into a full membership to elect Senator Romulo, thereby reducing another party’s fractional representation below its proportional share.
- This act was ruled a violation of the constitutional mandate on proportional representation.
- The Court emphasized that the specification of twelve members is a maximum cap, but proportional representation must guide membership selection—even if fractional membership results and some seats remain unfilled temporarily.
- The party breakdown must not be adjusted unilaterally by the majority to increase its own seats at the expense of minorities.
Historical and Precedential Considerations: Role of Senator Lorenzo Tanada’s Past Commission Membership
- The respondents invoked the membership of the late Senator Lorenzo Tanada in the CA in the 1950s-1960s as a precedent.
- The Court clarified that such past instances arose from coalitions formed by