Case Summary (G.R. No. 106971)
Applicable Law
The salient constitutional provision under consideration is Section 18 of Article VI of the 1987 Philippine Constitution, which lays down the framework for the creation and membership of the Commission on Appointments. This section mandates that the Commission comprises twelve senators and twelve representatives from the House of Representatives, elected based on proportional representation of the political parties.
Proportional Representation Controversy
The controversy centers on the election of Senators Romulo and Tanada to the Commission on Appointments. The petitioners argue that the election violates the principle of proportional representation found in the Constitution. The Senate, being composed of 15 members from the LDP (Liberal Democratic Party), 5 from NPC, 3 from LAKAS-NUCD, and 1 from LP-PDP-LABAN, claims to have calculated their representation proportions correctly. However, the petitioners contend that this approach unduly increases the representation of the majority party (LDP) while diminishing the rightful representation of the minority parties (LAKAS-NUCD and NPC).
Petition for Prohibition
On September 23, 1992, Guingona, representing LAKAS-NUCD, filed a petition seeking a writ of prohibition against the respondents from sitting as members of the Commission on Appointments. The petition emphasizes that the compromise arrangement allowing the LDP to nominate eight senators, while the NPC received only two, infringes upon the minority parties' rights to proportional representation.
Constitutional Interpretation
The Court affirms that the issues presented in the petition are rooted in constitutional interpretation, particularly Section 18 of Article VI. The Court must determine whether the actions of the Senate in electing Senators Romulo and Tanada align with constitutional mandates. The well-established interpretations provide that proportional representation is a guideline that should be adhered to strictly, ensuring that no party exceeds its entitled representation.
Findings on Representation
Upon examination, the Court recognizes that fractional membership under the proportional representation model must be properly allocated. The petitioners successfully argue that converting fractional memberships of parties into whole numbers undermines the proportional representation principle. The LDP's actions in nominating Romulo and Tanada led to an improper representation, clearly violating the Constitution.
Impact on Minority Parties
The decision emphasizes the necessity to uphold the balance of power within the Senate by adhering strictly to the rule of proportional representation. By allowing the majority party to effectively "round up" its representation at the expense of minority parties, the integrity of the Commission on Appointments is compromised.
Rulings and Consequences
The Court ultimately rules that the election of Senators Romulo and Tanada to the Commission violates Section 18 of Article VI. As a result, a writ of prohibition is issued, which mandates the respondents to cease their actions as members
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Case Background
- The case arises from a petition for Prohibition filed by Teofisto T. Guingona, Jr. and Lakas-NUCD against Senators Alberto Romulo and Wigberto Tanada, who were seated as members of the Commission on Appointments.
- The petitioners sought to prevent the respondents from assuming their positions in the Commission, claiming that the election process violated the rule of proportional representation mandated by the 1987 Constitution.
Composition of the Senate
- Following the national elections on May 11, 1992, the Senate's composition was outlined:
- LDP (Liberal Democratic Party) – 15 Senators
- NPC (Nationalist People's Coalition) – 5 Senators
- Lakas-NUCD – 3 Senators
- LP-PDP-LABAN – 1 Senator
- The mathematical formula for determining proportional representation was established, resulting in the following:
- LDP – 7.5 members
- NPC – 2.5 members
- Lakas-NUCD – 1.5 members
- LP-PDP-LABAN – 0.5 members
Nomination and Election Process
- During the Senate organization meeting on August 27, 1992, Senator Romulo nominated eight senators from the LDP for the Commission on Appointments.
- The nomination faced objections from Senators Guingona and Osmena, leading to a compromise proposed by Senator Tolentino, which was approved despite the minority's reservations.
- The elected members included eight from the LDP, one from LP-PDP-LABAN, two from NPC, and one from Lakas-NUCD.