**Facts:**
1. The case stems from the party-list elections held during the Philippine General Elections of 2007.
2. A series of litigations concerning the party-list representation and the computation of the seats for party-list groups erupted.
3. BANAT questioned the seat allocation methodology and the threshold requirements after the 2007 elections.
4. The House of Representatives, through Speaker Prospero C. Nograles, filed a motion for clarification regarding the discrepancy in the number of legislative districts and the corresponding party-list seats.
5. Armi Jane Roa-Borje, third nominee of Citizens’ Battle Against Corruption (CIBAC), filed a motion for partial reconsideration-in-intervention, challenging the party-list seat distribution that she alleged favored smaller parties.
6. Additionally, the COMELEC issued National Board of Canvassers (NBC) Resolution No. 09-001, which updated the election data but needed rectification as per the Court’s decision dated April 21, 2009.
7. The procedural path saw these issues consolidated and reviewed by the Supreme Court to address the method of party-list representation and distribution of seats.
**Issues:**
1. **Legislative Discrepancy:** Clarification if there are 219 or 220 legislative districts affecting the number of party-list seats.
2. **Maximum House Membership:** Whether to enroll all 32 party-list representatives named in Table 3 or limit to complete the 250-member maximum prescribed by the Constitution.
3. **Constitutional Violation:** Potential violation of the constitutional member limit of the House if all 32 party-list representatives are admitted.
4. **2% Threshold Application:** Clarification if the term “additional seats” refers to 2nd and 3rd seats only, and if the 2% rule applies to all remaining seats.
5. **Veterans Principle:** If the Veterans doctrine stating that filling up party-list seats is not mandatory has been abandoned.
**Court’s Decision:**
1. **Legislative Discrepancy:** The Court noted that there were only 219 legislative districts after the annulment of the creation of the Province of Shariff Kabunsuan.
2. **Maximum House Membership:** The maximum number of House Representatives should conform with the increment allowing for up to 54 party-list seats corresponding to 219 legislative districts.
3. **Constitutional Violation:** Including all 32 party-list representatives in the Roll of Members does not violate Section 5(1) of Article VI of the 1987 Constitution, given the legislative allotment framework.
4. **2% Threshold Application:** The 2% threshold rule applies to the initial allocation of seats but not to the additional rounds of seat allocation, thus ensuring compliance with constitutional mandates for proportional party-list representation.
5. **Veterans Principle:** The principle that filling up all available party-list seats is not mandatory remains valid. The Court maintained that the computation should ensure proportional representation as closely aligned with the Constitution.
**Doctrine:**
– The Court underscored that Section 5(2) of Article VI of the 1987 Constitution highlights the mathematical formula to determine party-list seats, emphasizing that these should constitute 20% of the House membership.
– The 2% threshold in allocating guaranteed seats is constitutional, but its application for additional seat allocation beyond initial guaranteed seats is unconstitutional as it hinders full party-list seat optimization.
– Legislation that increases the number of House members through additional legislative districts inherently increases corresponding party-list seats using a uniform ratio without excess legal requirement.
**Class Notes:**
– **Key Elements/Concepts:**
– **Legislative Districts:** Allocated according to population-based proportional representation.
– **Party-List System:** Designed to constitute 20% of House members.
– **2% Threshold:** Valid for initial allocation but not for additional rounds.
– **Three-Seat Cap:** To avoid domination by single party-list groups.
– **Section 5(1), Article VI of the 1987 Constitution** – House members should not exceed 250 unless amended by law.
– **Statutory Provisions:**
– **R.A. No. 7941:** Framework for party-list system, including the 2% rule and three-seat cap.
– **Section 11(b):** Outlines allocation methodology for party-list seats.
– **Application/Interpretation:**
– Ensures represented marginalized/relevant sectors proportionally.
– Additional seats in a proportional manner irrespective of guaranteed seat boundary ensuring adherence to constitutionally mandated representation.
**Historical Background:**
The case situates itself in the context of the evolving Philippine electoral landscape post-1987 Constitution, primarily engaging structural dynamics in determining equitable representation. The case is significant in the legislative history as it addresses the calibration between growing legislative districts and corresponding party-list representation, touching upon practical and constitutional balancing within the representative democracy set forth by the 1987 Constitution. The evolving jurisdiction and interpretation of COMELEC and legislative norms have witnessed amendments and interpretations ensuring dynamic political inclusivity.
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