**ANGKLA: Ang Partido ng mga Pilipinong Marino, Inc. v. Commission on Elections**
### Facts:
**1. Initial Legal Dispute:**
– **Petitioners:** ANGKLA: Ang Partido ng Mga Pilipinong Marino, Inc. (ANGKLA) and Serbisyo sa Bayan Party (SBP).
– **Respondent:** Commission on Elections (COMELEC), acting as the National Board of Canvassers.
– **Issue:** Constitutionality of the provision in Section 11(b) of Republic Act No. 7941 (Party-List System Act) about the allocation of seats to party-list parties proportional to their total number of votes.
**2. Procedural Background:**
– **2019 Elections:** COMELEC declared the winning party-list groups based on Section 11(b) RA 7941 and the established BANAT formula.
– **Initial Supreme Court Decision:** On September 15, 2020, the Supreme Court upheld the constitutionality of Section 11(b), denying the petitioners’ challenge.
– **Motion for Reconsideration:** ANGKLA and SBP sought reconsideration, claiming that the allocation method violates the “one person, one vote” principle.
### Issues:
**1. Constitutionality of Section 11(b) of RA 7941:**
– Whether Section 11(b) of RA 7941, making additional seat allocations proportional to total votes, violates the “one person, one vote” policy and the equal protection clause.
### Court’s Decision:
**1. Upholding the Constitutionality of Section 11(b) RA 7941:**
– **Assertion:** No constitutional violation exists. The Court reaffirms its earlier decision, holding that the BANAT formula effectively and fairly implements the law.
– **Evaluation of Arguments:** Addressed the petitioners’ claim regarding the double counting of votes while clarifying that the system involves two separate rounds for different purposes:
– **Round 1:** Assigns guaranteed seats based on a 2% vote threshold.
– **Round 2, Part 1:** Allocates additional seats proportionally.
– **Round 2, Part 2:** Distributes remaining seats among the next higher-ranked parties.
**2. Detailed Analysis of Petitioners’ Proposal:**
– The petitioners’ suggested deduction of the 2% threshold from the votes before Round 2 was rejected as it lacked textual basis in the law and diverged from legislative intent.
– **Equality and Fairness:** The established mechanism by Congress, including the 2% threshold and three-seat cap, seeks to balance representation in a structured manner within its discretion.
### Doctrine:
**1. BANAT Doctrine:**
– The system described in the BANAT v. Commission on Elections decision, which provides operational mechanics for seat allocation, continues to be the binding legal standard.
**2. Judicial Limitation:**
– Courts should not engage in judicial legislation by redefining or expanding statutory formulas contrary to textual and legislative directives without clear constitutional violations.
### Class Notes:
**Key Elements and Concepts:**
1. **Party-List System:** Governed by RA 7941; allocates seats based on proportional representation while ensuring minority and marginalized groups have legislative representation.
2. **Legislative Discretion:** Congress has significant latitude to establish parameters for electoral systems.
3. **Judicial Restraint:** Courts interpret but do not alter or rewrite legislative criteria unless constitutionally mandated.
4. **Proportionality Principle:** Ensures votes are fairly translated into representation through established thresholds and limits.
**Statutory Provision:**
– **Section 11(b), RA 7941:** Dictates the formula for seat allocation, including:
– Guaranteed one seat for party-lists receiving at least 2% of votes.
– Additional seats proportional to the total votes.
– Caps at three seats per party-list organization.
### Historical Background:
– **Context:** RA 7941 instituted the party-list system in response to demands for broader representation and inclusivity within the legislative framework.
– **Evolution:** The formula, including the BANAT decision, reflects ongoing adjustments to best represent a plurality of interests in Philippine legislative processes.
This detailed brief provides clarity and comprehensive legal treatment of the issues, reflecting on historical developments and statutory interpretations relevant to the party-list system in Philippine jurisprudence.
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