### Facts:
In a detailed series of procedural steps leading to the Supreme Court, the case involves the proclamation of additional nominees by the Commission on Elections (COMELEC) from various party-lists, contrary to a prior Temporary Restraining Order issued by the Court. The COMELEC, in its Resolution No. NBC-02-001, dated November 6, 2002, and subsequent orders in November 2002, proclaimed additional seats for APEC, AKBAYAN, BUTIL, CIBAC, and others based on the percentage of votes they received in the May 2001 elections. These actions were challenged for violating the Temporary Restraining Order and the principles of proportional representation outlined in Republic Act No. 7941 (Party-List System Act) and precedent jurisprudence. The matter reached the Supreme Court, which initially put a halt to these actions and later entered into resolutions discussing the legitimacy of these proclamations and entitlements to additional seats under the party-list system.
### Issues:
1. Whether the proclamation by the COMELEC of the additional nominees of APEC, BUTIL, CIBAC, and AKBAYAN, after the issuance of the Court’s Temporary Restraining Order, was valid.
2. Whether BUHAY is entitled to one additional seat in the party-list system based on the proportion of votes it received in the May 2001 elections.
### Court’s Decision:
1. **On the Legitimacy of Proclamations**: The Court affirmed the prohibition against the COMELEC’s proclamation of additional nominees as a violation of its Temporary Restraining Order and the principles established in prior jurisprudence regarding the allocation of party-list seats. However, considering those nominees had already taken oath and assumed office, the Court pro hac vice considered the issue regarding their proclamation closed and terminated.
2. **On BUHAY’s Entitlement**: In deciding in favor of BUHAY’s entitlement to one additional seat, the Court applied the principle of proportional representation. It calculated the percentage of votes obtained by BUHAY in the elections and determined that based on the votes they received (4.46% of the total party-list votes), they were entitled to an additional seat under the party-list system as per the formulas established in prior jurisprudence.
### Doctrine:
The case reiterates the doctrine related to the allocation of party-list seats based on proportional representation, particularly emphasizing the capped maximum number of seats that a party-list can obtain and the prohibition against altering final and executory decisions of the Supreme Court by other entities like the COMELEC.
### Class Notes:
– **Proportional Representation**: The essence of the party-list system wherein seats are allocated based on the proportion of votes received, ensuring a broad and fair representation of parties.
– **Temporary Restraining Order**: A court order to temporarily suspend proceedings or actions, which binds parties until further orders.
– **RA 7941 (Party-List System Act)**: The governing law for the conduct of party-list elections in the Philippines, embedding the principle of proportional representation and setting the framework for the allocation of seats in the House of Representatives.
### Historical Background:
The case sits against the backdrop of the evolving jurisprudence on the party-list system in the Philippines, aiming to refine and apply the principles of proportional representation and fair allocation of seats within the legislative framework established by RA 7941. It reflects the tension between the administrative actions of electoral bodies like the COMELEC and the supervisory jurisdiction of the Supreme Court in ensuring the adherence to constitutional principles and legislative mandates.
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