Party-List System Cases | Republic Act No. 7491 PDF

PSC1203— Republic Act No.7491— Republic Act No. 7491 AN ACT PROVIDING FOR THE ELECTION OF PARTY-LIST REPRESENTATIVES THROUGH THE PARTY-LIST SYSTEM, AND APPROPRIATING FUNDS THEREFOR. https://www.set.gov.ph/resources/election-law/repub...

PSC1203— Republic Act No.7491— Republic Act No. 7491 AN ACT PROVIDING FOR THE ELECTION OF PARTY-LIST REPRESENTATIVES THROUGH THE PARTY-LIST SYSTEM, AND APPROPRIATING FUNDS THEREFOR. https://www.set.gov.ph/resources/election-law/republic-act-no-7491/ Cases to Read: 1. Veterans Federation Party v. Commission on Elections (G.R. No. 136781, October 6, 2000) 2. Ang Bagong Bayani v. Commission on Elections (G.R. No. 147589, June 26, 2001) 3. Barangay Association for National Advancement and Transparency (BANAT) v. Commission on Elections (G.R. No. 179271, April 21, 2009) 4. Partido ng Manggagawa (PM) and BUTIL v. Commission on Elections (G.R. No. 164702) 5. Atong Paglaum, Inc. v. Commission on Elections (G.R. No. 203766, April 2, 2013) 6. Komunidad ng Pamilya, Pasyente at Persons with Disabilities (P3PWD) v. Commission on Elections (G.R. No. 261889, November 21, 2024) 7. A Waray Party-List v. Commission on Elections (G.R. No. 259931, September 16, 2024) 8. Bayan Muna v. Commission on Elections (G.R. No. 179295, April 21, 2009) 9. Abono Party List v. Commission on Elections (G.R. No. 179295, April 21, 2009) 10. A Teacher Party List v. Commission on Elections (G.R. No. 179295, April 21, 2009) Case Digest: 1. Veterans Federation Party v. Commission on Elections (G.R. No. 136781, October 6, 2000) Case Digest: Veterans Federation Party vs. COMELEC G.R. No. 136781 | October 6, 2000 | En Banc PSC1203— 1  Facts: The 1987 Constitution introduced the party-list system to provide representation for marginalized and underrepresented sectors in Congress. Republic Act No. 7941 (Party-List System Act) outlined the mechanics of the system, including the 2% vote threshold for a party to secure a seat and a 3-seat cap per party. During the May 11, 1998 elections, 13 party-list groups met the 2% requirement, securing 14 seats in the House of Representatives (one group obtained two seats). However, the Commission on Elections (COMELEC) later proclaimed 38 additional party-list representatives, disregarding the 2% rule to ensure the full 20% allocation of party-list seats in Congress. Several petitioners, including the Veterans Federation Party, challenged COMELEC’s ruling, arguing that the 2% threshold and 3-seat cap should be upheld. The case was brought before the Supreme Court through a Petition for Certiorari under Rule 65 of the Rules of Court. Issues: 1. Is the 20% allocation of party-list seats in the House of Representatives mandatory or merely a ceiling? 2. Are the 2% vote threshold and 3-seat cap constitutional? 3. What is the proper method for allocating additional seats to qualified parties? Ruling: The Supreme Court ruled in favor of the petitioners, setting aside COMELEC’s resolutions and upholding the 2% vote threshold and 3-seat cap. 1. The 20% allocation is merely a ceiling, not a mandatory number of seats to be filled. If there are not enough qualified parties to fill the full 20% allocation, the remaining seats should not be given to unqualified parties. 2. The 2% threshold and 3-seat cap are constitutional. These requirements ensure that party-list seats go only to groups with significant public support while promoting proportional representation. 3. The proper method of allocating additional seats must follow a proportional system. The "first party rule" was established, wherein the party with the highest votes determines the allocation formula for additional seats among the other qualified parties. PSC1203— 2  Thus, the Supreme Court nullified COMELEC's resolution, allowing only the 14 original representatives to retain their seats. Opinion: The majority opinion, penned by Justice Artemio Panganiban, emphasized that COMELEC exceeded its authority by ignoring clear legal requirements. It ruled that Congress, not COMELEC, has the power to amend election laws, and the judiciary must enforce these laws as written. Justice Vicente Mendoza, in his dissenting opinion, argued that the proportional representation formula used by the majority was too strict and failed to achieve broader sectoral representation. However, the majority maintained that their interpretation best adhered to constitutional and statutory requirements. Doctrine Established: The 20% allocation of party-list seats is a ceiling, not a mandatory requirement. The 2% threshold and 3-seat cap are valid and enforceable. Seats must be distributed proportionally based on votes received, using the "first party rule." Disposition: The Supreme Court set aside COMELEC’s resolutions and affirmed the proclamation of only 14 party-list representatives who met the 2% threshold. 2. Ang Bagong Bayani v. Commission on Elections (G.R. No. 147589, June 26, 2001) Case Digest: Ang Bagong Bayani-OFW Labor Party v. Commission on Elections G.R. No. 147589 & G.R. No. 147613 | June 26, 2001 Facts: The Commission on Elections (COMELEC) issued Omnibus Resolution No. 3785, allowing 154 organizations, parties, and coalitions to participate in the 2001 party-list elections. Among these were major political parties and non-marginalized organizations. Petitioners Ang Bagong Bayani-OFW Labor Party and Bayan Muna challenged the resolution, arguing that only marginalized and underrepresented sectors should be allowed to participate in the PSC1203— 3  party-list system, as intended by the 1987 Constitution and Republic Act No. 7941 (Party- List System Act). The petitioners sought the disqualification of traditional political parties and groups that do not represent marginalized sectors, claiming that COMELEC committed grave abuse of discretion in accrediting them. The Supreme Court was asked to resolve whether the party-list system is open to all organizations or exclusive to marginalized sectors. Issues: 1. Is the party-list system exclusively for marginalized and underrepresented sectors? 2. Did the COMELEC commit grave abuse of discretion in allowing major political parties to participate? 3. Should political parties be disqualified from participating in the party-list elections? Ruling: 1. The party-list system is intended for marginalized and underrepresented sectors. The Supreme Court ruled that the primary objective of the party-list system is to provide representation for marginalized and underrepresented groups, ensuring that they have a voice in Congress. It is not meant to be an alternative route for dominant political parties to gain additional seats. 2. COMELEC committed grave abuse of discretion. The Court found that COMELEC failed to properly screen party-list applicants, allowing non-marginalized groups and major political parties to participate. It remanded the case to COMELEC, ordering it to conduct a thorough review of the accredited groups. 3. Political parties may participate, but only if they represent marginalized sectors. While the Constitution and RA 7941 do not explicitly prohibit political parties from joining the party-list elections, they must prove that they genuinely represent marginalized and underrepresented sectors. Traditional political parties that dominate congressional district elections should not be allowed to contest party-list seats. Opinion: The Supreme Court set guidelines for COMELEC to follow in screening party-list candidates, emphasizing that: The party-list system is a social justice tool meant for sectors that have been historically underrepresented. PSC1203— 4  A political party may participate only if it represents marginalized groups, and its nominees must belong to those sectors. Government-supported organizations or groups affiliated with powerful political entities should not be allowed to join the party-list system. Justice Panganiban, writing for the majority, highlighted that allowing powerful political groups to join the party-list elections would defeat the system’s purpose. Meanwhile, Justices Vitug and Mendoza dissented, arguing that the Constitution does not limit party-list participation to marginalized sectors alone. Doctrine Established: The party-list system is for marginalized and underrepresented sectors. Political parties may participate only if they genuinely represent such sectors. COMELEC must ensure that the party-list system is not exploited by dominant political parties. Disposition: The Supreme Court remanded the case to COMELEC and barred the proclamation of unqualified party-list winners until proper screening was conducted. It upheld the spirit of the party-list system as a means of empowering the marginalized. 3. Barangay Association for National Advancement and Transparency (BANAT) v. Commission on Elections (G.R. No. 179271, April 21, 2009) Case Digest: Barangay Association for National Advancement and Transparency (BANAT) v. Commission on Elections G.R. No. 179271 | April 21, 2009 Facts: In the 2007 elections, BANAT (Barangay Association for National Advancement and Transparency) filed a petition before the Commission on Elections (COMELEC), arguing that the full 20% allocation of party-list seats in the House of Representatives must be filled as provided in Section 5, Article VI of the 1987 Constitution. COMELEC, applying the Veterans Federation Party formula, only proclaimed 13 parties that met the 2% threshold, leaving some seats unfilled. BANAT sought to invalidate the threshold PSC1203— 5  requirement, claiming it prevented proportional representation. COMELEC dismissed BANAT’s petition as moot, leading BANAT to file a petition for certiorari and mandamus with the Supreme Court. Issues: 1. Is the 20% allocation for party-list representatives a mandatory requirement or a mere ceiling? 2. Is the 2% vote threshold for additional seats constitutional? 3. Is the 3-seat cap per party constitutional? 4. How should party-list seats be allocated? Ruling: 1. The 20% allocation is a ceiling, not a mandatory requirement. The Court ruled that while the Constitution allows up to 20% of House seats for party-list representatives, this number does not have to be fully met if not enough parties qualify. 2. The 2% threshold for additional seats is unconstitutional. The Court found that the threshold prevented full seat allocation and violated the principle of proportional representation. 3. The 3-seat cap remains valid. This prevents dominant parties from monopolizing the party-list system. 4. A new formula for seat allocation was established: Parties with at least 2% of total votes automatically get one seat. The remaining seats are distributed proportionally based on total votes. No party can hold more than three (3) seats. With this ruling, the number of party-list representatives increased, ensuring that more parties received seats in Congress. Opinion: The Court emphasized the need for proportional representation and rectified the flaws in the Veterans Federation Party formula. Justice Antonio Carpio, writing for the majority, ruled that COMELEC erred in limiting party-list seats. The 2% threshold was removed because it artificially restricted representation and failed to maximize the available seats. PSC1203— 6  However, the Court upheld the 3-seat cap to prevent political parties from dominating the party-list system. The ruling significantly reshaped party-list elections, ensuring that more marginalized groups gain representation in Congress. Doctrine Established: The 20% party-list allocation is a ceiling, not a mandatory requirement. The 2% threshold for additional seats is unconstitutional. Party-list seats should be allocated proportionally to maximize representation. The 3-seat cap remains valid. Disposition: The Supreme Court granted BANAT’s petition, struck down the 2% threshold, and remanded the case to COMELEC for the reallocation of party-list seats using the new formula. 4. Partido ng Manggagawa (PM) and BUTIL v. Commission on Elections (G.R. No. 164702) Case Digest: Partido ng Manggagawa (PM) and Butil Farmers Party v. Commission on Elections (COMELEC) G.R. No. 164702 | March 15, 2006 Facts: In the 2004 party-list elections, several party-list groups, including Partido ng Manggagawa (PM) and Butil Farmers Party (BUTIL), won seats. COMELEC applied Resolution No. 6835, using a simplified seat allocation formula—"one additional seat per additional two per cent of the total party-list votes." Petitioners PM and BUTIL, along with CIBAC, filed a Joint Motion for Immediate Proclamation, arguing that the correct formula for additional seats should be based on the Supreme Court's ruling in Veterans Federation Party v. COMELEC, which followed a proportional representation method. COMELEC denied their request. PM and BUTIL then filed a petition for mandamus before the Supreme Court, arguing that COMELEC had the ministerial duty to follow the Veterans Federation formula instead of its simplified version. Issues: PSC1203— 7  1. Did COMELEC commit grave abuse of discretion in using its simplified formula instead of the Veterans Federation Party formula? 2. What is the correct method for computing additional party-list seats? 3. Is COMELEC’s duty to apply the correct formula ministerial or discretionary? Ruling: 1. COMELEC committed grave abuse of discretion by not applying the Veterans Federation Party formula and instead using its simplified method. The Supreme Court ruled that the proportional representation formula established in Veterans should be followed to ensure fairness in the party-list seat allocation. 2. The correct method for computing additional seats is the Veterans Federation Party formula, which states that: All parties meeting the 2% threshold get one seat each. The first party (highest vote-getter) determines the proportional distribution of additional seats. The remaining seats are distributed based on the ratio of votes received by each party about the first party. The 3-seat cap per party remains valid. 3. COMELEC’s duty is ministerial, not discretionary. Since the Supreme Court has already set the formula, COMELEC has no discretion to modify it. The Court ruled that COMELEC must apply the formula as decided in the Veterans Federation Party. Opinion: Justice Reynato Puno, writing for the Court, emphasized that: The party-list system is a means for marginalized sectors to be represented in Congress. COMELEC has no authority to change or simplify the allocation method set by the Supreme Court. The Supreme Court has the final say in interpreting election laws, and COMELEC must comply. Some justices dissented, arguing that COMELEC should have discretion in administering elections, but the majority held that judicial precedent must be followed. PSC1203— 8  Doctrine Established: COMELEC must follow the Supreme Court's ruling on party-list seat allocation. The Veterans Federation Party formula is the correct method for distributing additional seats. COMELEC’s role in applying election laws is ministerial, not discretionary. Disposition: The Supreme Court granted the petition, ordered COMELEC to follow the Veterans Federation Party formula, and directed it to recompute and reallocate party-list seats accordingly. 5. Atong Paglaum, Inc. v. Commission on Elections (G.R. No. 203766, April 2, 2013) Case Digest: Atong Paglaum, Inc. v. Commission on Elections (G.R. No. 203766, April 2, 2013) Facts: Several party-list groups, including Atong Paglaum, Inc., filed petitions against the Commission on Elections (COMELEC) after their registrations were denied or cancelled. COMELEC ruled that these groups failed to meet the qualifications under Republic Act No. 7941 (Party-List System Act) and the guidelines set in Ang Bagong Bayani v. COMELEC, which limited party- list participation to marginalized and underrepresented sectors. The petitioners argued that the stringent requirements imposed by COMELEC were inconsistent with the Constitution. Issues: 1. Whether the COMELEC committed grave abuse of discretion in cancelling or denying the registration of petitioners based on Ang Bagong Bayani guidelines. 2. Whether political parties and groups that do not represent marginalized sectors can participate in the party-list system. Ruling: The Supreme Court ruled in favour of Atong Paglaum, Inc. and other petitioners. It overturned the Ang Bagong Bayani guidelines and held that political parties, regardless of whether they represent marginalized sectors, may participate in the party-list system. The Court clarified that PSC1203— 9  the party-list system was intended not just for sectoral representation but also for political parties, provided they meet the legal requirements under R.A. 7941. The Court ordered the remand of cases to COMELEC for reconsideration of the disqualified groups under the new standard. Opinion: The decision significantly expanded access to the party-list system, allowing political parties to participate without having to prove representation of marginalized sectors. This ruling shifted the interpretation of the party-list system from an exclusive mechanism for marginalized groups to a broader system of proportional representation. 6. Komunidad ng Pamilya, Pasyente at Persons with Disabilities (P3PWD) v. Commission on Elections (G.R. No. 261889, November 21, 2024) 7. A Waray Party-List v. Commission on Elections (G.R. No. 259931, September 16, 2024) 8. Bayan Muna v. Commission on Elections (G.R. No. 179295, April 21, 2009) 9. Abono Party List v. Commission on Elections (G.R. No. 179295, April 21, 2009) 10. A Teacher Party List v. Commission on Elections (G.R. No. 179295, April 21, 2009) PSC1203— 10