G.R. No. 86344 December 21, 1989
REP. RAUL A. DAZA, petitioner, vs. REP. LUIS C. SINGSON and HON. RAOUL V. VICTORINO IN THE LATTER’S CAPACITY AS SECRETARY OF THE COMMISSION ON APPOINTMENTS, respondents.

FACTS

Following the 1987 congressional elections, the House of Representatives apportioned its twelve seats in the Commission on Appointments (CA) based on proportional representation among political parties, as mandated by Article VI, Section 18 of the Constitution . Petitioner Raul Daza was elected as a representative of the Liberal Party. Subsequently, on September 16, 1988, a political realignment occurred with the reorganization of the Laban ng Demokratikong Pilipino (LDP). Twenty-four members of the Liberal Party resigned and joined the LDP, increasing its membership to 159 and reducing the Liberal Party to 17 members.
Based on this development, the House revised its representation in the CA. It withdrew the seat occupied by Daza and reassigned it to the LDP. On December 5, 1988, the House elected a new set of representatives, excluding Daza and including respondent Luis Singson as the additional member from the LDP. Daza challenged his removal before the Supreme Court, arguing his election to the CA was permanent under the doctrine of Cunanan v. Tan and that the LDP, not being a duly registered party, could not justify the realignment.

ISSUE

The core issue is whether the House of Representatives acted with grave abuse of discretion or in violation of the Constitution when it removed petitioner Daza from the Commission on Appointments following a political realignment.

RULING

The Supreme Court dismissed the petition, upholding the House’s authority to change its representation in the CA. The Court first addressed the jurisdictional challenge, ruling that the case presented a justiciable, not a political, question. The petition questioned the legality of the House’s act under the constitutional provision on proportional representation, not the wisdom or policy behind it. The Court emphasized its expanded judicial power under Article VIII, Section 1 to review acts of any government branch for grave abuse of discretion.
On the substantive issue, the Court interpreted Article VI, Section 18, which requires CA membership to be based on “proportional representation from the political parties… represented therein.” The constitutional intent is to ensure the CA’s composition reflects the current relative strengths of the political parties in the House. A significant and permanent shift in party affiliation—such as the mass transfer of 24 members from the Liberal Party to the LDP—constitutes a change in proportional representation that the House is constitutionally bound to recognize. The Court held that the House acted correctly in realigning its CA seats to mirror this new political reality. The requirement for proportional representation is dynamic, allowing for adjustments to maintain its constitutional fidelity whenever a permanent political realignment occurs. The temporary restraining order was lifted, and respondent Singson was declared entitled to assume the CA seat.