Partido ng Manggagawa v. Commission on Elections
REITERATIONFacts
The Antecedents: Several party-list participants inquired about the formula for computing additional seats for party-list winners in the May 10, 2004 elections. The Commission on Elections (COMELEC) issued Resolution No. 6835, adopting a simplified formula of "one additional seat per additional two percent of the total party-list votes." Procedural History: Petitioners Partido ng Manggagawa (PM) and Butil Farmers Party (BUTIL), along with CIBAC, filed a Joint Motion for Immediate Proclamation, praying for an additional seat each, citing a different formula from the Ang Bagong Bayani case. The COMELEC, through Resolution No. NBC 04-011, directed a re-tabulation of votes for certain parties, referencing the simplified formula in Resolution No. 6835. Petitioners then filed the instant petition for mandamus. The Petition: Petitioners sought to compel the COMELEC to convene as the National Board of Canvassers, declare them entitled to an additional seat each, proclaim their second nominees, and do the same for other similarly situated party-list organizations. The sole issue presented was whether the COMELEC could be compelled to mechanically apply the formula stated in its June 25, 2003 Resolution, reiterated in the November 20, 2003 Resolution in the Ang Bagong Bayani cases.
Issue(s)
Whether the petition for mandamus was the proper remedy. Whether the petition was filed out of time. Whether a motion for reconsideration of COMELEC Resolution No. 6835 was necessary. Whether the COMELEC could be compelled to mechanically apply the formula stated in its June 25, 2003 Resolution, reiterated in the November 20, 2003 Resolution in the Ang Bagong Bayani cases, for the determination of qualified party-list organizations and the proclamation of their nominees. What is the correct formula for computing additional seats for party-list winners?
Ruling
The petition is DENIED. The COMELEC is directed to apply the formula established in Veterans Federation Party v. COMELEC.
Ratio Decidendi
On the propriety of Mandamus: The Court held that mandamus lies to compel the performance of a ministerial duty. While the COMELEC's duty to proclaim nominees might be discretionary, its duty to apply the formula as decided by the Supreme Court, which has the ultimate authority to interpret laws, is ministerial. The COMELEC has no discretion to refuse enforcement of a Supreme Court decision. Furthermore, the Court stated that the averments in the complaint, not its nomenclature, determine the nature of the action, and the petition could be treated as one for certiorari and mandamus due to allegations of grave abuse of discretion and acting without jurisdiction. On timeliness of the petition: The Court found the petition timely filed. It clarified that the 30-day period under Article IX(A), Section 7 of the Constitution and Rule 64, Section 3 of the Rules of Court applies to final orders, rulings, and decisions rendered in the exercise of adjudicatory or quasi-judicial powers. Resolution No. 6835 was issued in the exercise of COMELEC's administrative function to enforce election laws, not its quasi-judicial powers. The petition was filed within 18 days of COMELEC Resolution No. NBC 04-011, which directed a re-tabulation based on the contested formula. On the necessity of a motion for reconsideration: The Court ruled that a motion for reconsideration of an en banc ruling of the COMELEC is not allowed under Rule 13, Section 1(d) of the COMELEC Rules of Procedure. Moreover, the issue of which formula to apply in determining additional seats is a pure question of law, which is a recognized exception to the rule on exhaustion of administrative remedies. On the formula for additional seats: The Court reiterated that the formula established in the landmark case of Veterans Federation Party v. COMELEC prevails. The Court emphasized that the formulas devised in Veterans for computing the number of nominees for party-list winners cannot be disregarded by government agencies, including the COMELEC, as they ensure proportional representation. The Court clarified that the November 20, 2003 Resolution in Ang Bagong Bayani, which granted an additional seat to BUHAY, was qualified as pro hac vice (for this one particular occasion) and thus cannot be relied upon as a precedent. The Court applied the Veterans formula to the undisputed figures and found that petitioners PM and BUTIL were not entitled to any additional seats, as their computed additional seats were 0.74 and 0.71, respectively, which are less than one. Application of the Veterans formula: The Court applied the formula: Additional seats for concerned party = (No. of votes of concerned party) / (No. of votes of the first party) (No. of additional seats allocated to first party). For PM, this was (448,072 / 1,203,305) 2 = 0.74. For BUTIL, this was (429,259 / 1,203,305) 2 = 0.71. Since these figures are less than one, they are not entitled to an additional seat.
Main Doctrine
The formula for computing additional seats for party-list winners, as established in Veterans Federation Party v. COMELEC, remains the prevailing rule. A ruling qualified as pro hac vice cannot serve as precedent for other cases.