Daza v. Singson
REITERATIONFacts
The Antecedents: Following the May 11, 1987 congressional elections, the House of Representatives proportionally apportioned its twelve seats in the Commission on Appointments among various political parties. Petitioner Raul A. Daza was chosen as a representative of the Liberal Party. Procedural History: On September 16, 1988, the Laban ng Demokratikong Pilipino (LDP) was reorganized, leading to a political realignment where 24 members of the Liberal Party joined the LDP. Consequently, the House revised its representation in the Commission on Appointments, withdrawing petitioner Daza's seat and assigning it to the LDP, with respondent Luis C. Singson being elected to fill it. Petitioner Daza filed a petition for prohibition and injunction with the Supreme Court, challenging his removal and the respondent's assumption of the seat, leading to a temporary restraining order. The Petition: Petitioner argued that his election to the Commission on Appointments was permanent under the doctrine of Cunanan v. Tan, and that the reorganization was invalid because the LDP was not a duly registered political party and had not yet attained political stability. Respondent contended that the issue was political and beyond the Court's jurisdiction, that he was improperly impleaded, and that party registration was not a constitutional requirement for representation in the Commission.
Issue(s)
Whether the Supreme Court has jurisdiction over the petition challenging the House of Representatives' reorganization of its representation in the Commission on Appointments. Whether the removal of the petitioner from the Commission on Appointments and the seating of the respondent were valid, considering the reorganization of the House representation based on the formation of the LDP. Whether the LDP, not being a duly registered political party at the time of the reorganization, was entitled to proportional representation in the Commission on Appointments.
Ruling
The petition is DISMISSED. The temporary restraining order dated January 13, 1989, is LIFTED. The Court holds that the respondent has been validly elected as a member of the Commission on Appointments and is entitled to assume his seat in that body pursuant to Article VI, Section 18, of the Constitution.
Ratio Decidendi
On Issue 1: The Supreme Court held that it has jurisdiction over the petition. The issue presented is not a political question but a justiciable one concerning the legality of the House of Representatives' act in removing the petitioner from the Commission on Appointments, not its wisdom. Even if it were considered a political question, the Court's expanded jurisdiction under Article VIII, Section 1 of the Constitution, which includes the duty to determine grave abuse of discretion amounting to lack or excess of jurisdiction, allows for review. The objection regarding the respondent being improperly impleaded was also set aside due to the transcendental importance of the constitutional issues involved, allowing the Court to treat the proceeding as a petition for quo warranto or to brush aside technicalities to address the core constitutional question. On Issue 2: The Court ruled that the House of Representatives has the authority to change its representation in the Commission on Appointments to reflect permanent changes in the political alignments of its membership. The formation of the LDP, which absorbed a significant number of members from other parties, constituted a permanent change justifying the reorganization. The Court distinguished this from temporary alliances, citing Cunanan v. Tan which invalidated a reorganization based on a temporary coalition. The Court found that the respondent was validly elected to the Commission on Appointments based on the revised proportional representation. On Issue 3: The Court addressed the petitioner's argument that the LDP, not being a registered political party, was not entitled to representation. However, subsequent to the filing of the petition, the Commission on Elections granted the LDP's petition for registration as a political party. This development rendered the petitioner's argument moot. Furthermore, the Court clarified that the Constitution does not explicitly require a political party to be registered to be entitled to proportional representation, although the subsequent registration of LDP removed this contention. The Court also rejected the petitioner's assertion that a party must pass the test of time or survive a general election to be recognized, citing the historical example of the Liberal Party's initial representation despite being newly formed.
Main Doctrine
The Supreme Court clarified that the House of Representatives possesses the authority to modify its representation in the Commission on Appointments to mirror any permanent shifts in political alignments within the chamber. This power is not absolute and is circumscribed by the requirement that such changes must be permanent, excluding mere temporary alliances or factional divisions. The Court also affirmed its jurisdiction to review the legality of such actions, even if they touch upon political questions, under its expanded judicial power, and dismissed the petition, upholding the validity of the respondent's election to the Commission.