**Facts**:
In 1992, a dispute arose regarding the composition of the Commission on Appointments (CA) in the Philippines. The specific contention was over whether the election of certain senators to the CA satisfied the constitutional requirement of “proportional representation” among political parties represented in the Senate as mandated by Article VI, Section 18 of the 1987 Constitution.
1. **Initial Decision**:
– On August 27, 1992, the Senate majority, composed primarily of the Laban ng Demokratikong Pilipino (LDP), elected Senators Romulo and Tañada to the CA despite objections from minority parties, particularly Lakas-NUCD.
– Petitioners Teofisto Guingona Jr. and Lakas-NUCD filed a case asserting that this election violated the constitutional provision on proportional representation because the allocation exceeded what LDP was entitled to and reduced the rightful representation of minority parties.
2. **Supreme Court Decision**:
– On October 20, 1992, the Supreme Court ruled in favor of the petitioners, finding that the election of Senators Romulo and Tañada violated Section 18 of Article VI due to misapplication of proportional representation.
3. **Motions for Reconsideration**:
– On October 27 and October 30, 1992, respondents Senators Tañada and Romulo, along with Senate President Neptali Gonzales, filed motions for reconsideration. Their arguments included claims of misappreciation of factual precedents, inconsistency with previous rulings (Coseteng vs. Mitra, Jr. and Daza vs. Singson), necessity to fill 12 seats, and compliance with a multi-party system.
– Additionally, the Nationalist People’s Coalition (NPC) filed a comment supporting reconsideration on December 16, 1992.
4. **Comments on Motions**:
– On January 7, 1993, petitioners filed separate comments opposing the motions for reconsideration.
**Issues**:
1. Whether the decision misappreciated relevant factual precedents.
2. Whether the decision ignored the reality and constitutional recognition of a multi-party system.
3. Whether it was compulsory to fill up 12 seats of the CA.
4. Whether the election of Senators Tañada and Romulo violated the constitutional requirement for proportional representation in the CA.
**Court’s Decision**:
1. **Misappreciation of Facts**:
– The court maintained that its appreciation of the facts was correct, emphasizing that the proportional representation required by Article VI, Section 18 must be strictly followed wherein fractional memberships should not be manipulated to unjustly increase representation for any party.
2. **Multi-Party System**:
– The court clarified that recognition of a multi-party system does not justify undermining the strict requirement for proportional representation in the CA. The multi-party system should not lead to misrepresentation or disenfranchisement of minority parties.
3. **Mandatory 12 Seats**:
– The court reiterated that the Constitution does not mandate filling exactly 12 seats at all costs. The primary requirement was proportional representation, which might result in fractional membership, and this rule takes precedence over the number.
4. **Proportional Representation Violation**:
– The court upheld its decision that the election of Senators Tañada and Romulo breached the proportional representation requirement, as converting fractional memberships into whole memberships distorted the balance intended by the law.
**Doctrine**:
– The constitutional mandate of proportional representation within the CA is paramount and must be observed strictly, even if this results in fractional membership.
– The concept of proportional representation serves as a check on the majority party’s power, ensuring that all political parties get representation commensurate with their actual presence in the Senate.
**Class Notes**:
– **Proportional Representation**: In constitutional contexts, especially in legislative bodies, this principle ensures that representation in committees or commissions mirrors the party composition in the larger legislative body. Relevant Statute: Article VI, Section 18 of the 1987 Constitution.
– **Grave Abuse of Discretion**: This case reiterates that grave abuse occurs when power is exercised in a manner grossly outside the bounds of the law. See: Guingona Jr. v. Gonzales.
– **Multi-Party System Considerations**: Recognition of multiple political parties must align with maintaining proportional representation, and practical coalition-building may be necessary to adhere to constitutional mandates.
– **Judicial Interpretation Role**: The Supreme Court is upheld as the final interpreter of constitutional provisions regarding proportional representation and the correct execution of related constitutional mandates.
**Historical Background**:
– This case reflects the ongoing dynamic and complex interplay between majority and minority parties in the Philippine legislative framework post-1987 Constitution, illustrating judicial oversight in maintaining constitutional balances.
– The importance of proportional representation in the Philippine legislature stems from historical efforts to ensure fairness and prevent dominance by any single party, fostering a multi-party democracy.
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