Raul Daza vs Luis Singson

G.R. No. 86344 – 259 Phil. 980 – 180 SCRA 496 – Political Law – The Legislative Branch – Sec. 18, Art. VI; The Lower House’s 12 Seats in the Commission on Appointments; Apportionment

After the 1988 elections, the lower house was dominated by the following parties: Lakas ng Bansa, the PDP-Laban, the NP-Unido, the Liberal Party, and the KBL. In accordance with Sec. 18, Art. VI of the 1987 Constitution which provides that “there should be a Commission on Appointments consisting of twelve Senators and twelve members of the House of Representatives elected by each House respectively on the basis of proportional representation,” the lower house had apportioned their 12 seats in the CoA proportionately. One of LP’s representative was Raul Daza. However in 1988, there was a political realignment in the lower house which saw 159 representatives resigning from their political parties to form (reorganize) the Laban ng Demokratikong Pilipino. The Liberal Party saw its number reduced from 41 to 17 which also resulted in the reduction of its proportional representation in the CoA which means that Raul Daza had to be replaced – the representative replacing him was Luis Chavit Singson of the LDP.

Daza, via a petition for prohibition, questioned his replacement on the ground that the LDP was not yet registered as a political party and has not yet attained finality. For his part, Singson moved for the dismissal of Daza’s petition on the ground that the issue of filling out the lower house’s 12 seats in the CoA is a political question as the same is under the discretion of the lower house and the wisdom behind it may not be questioned in court.

ISSUE: Whether or not a change resulting from a political realignment validly changes the composition of the Commission on Appointments.

HELD: Yes. The matter involved in this case is not a political question and even if it is, the same may still be resolved as what is being invoked in Daza’s petition is to determine whether or not there is grave abuse of discretion in the manner which the CoA seats were filled. Under Sec. 1, Art. VII, the court’s power of judicial review was expanded to include the power to determine whether or not there has been a grave abuse of discretion amounting to lack or excess of jurisdiction on the part of any branch or instrumentality of the Government.

Nevertheless, Daza’s replacement is valid. Daza’s primary argument that the LDP may not field representatives to the CoA because it is not a registered political party was mooted when the LDP was registered in 1989. As to the argument that LDP has not yet attained stability, the argument has no merit. It is true that there have been, and there still are, some internal disagreements among its members, but these are to be expected in any political organization, especially if it is democratic in structure. In fact even the monolithic Communist Party in a number of socialist states has undergone similar dissension, and even upheavals. But it surely cannot be considered still temporary because of such discord.

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