G.R. No. 172103 . April 13, 2007.
CITIZENS’ BATTLE AGAINST CORRUPTION (CIBAC), Petitioner, vs. COMMISSION ON ELECTIONS (COMELEC), represented by CHAIRMAN BENJAMIN ABALOS, SR., Respondent.

FACTS

In the May 2004 party-list elections, petitioner CIBAC was proclaimed entitled to one seat in Congress after garnering 3.9084% of the total party-list votes. The COMELEC, acting as the National Board of Canvassers, applied its self-promulgated “simplified formula” from Resolution No. 6835, which granted one additional seat for every additional 2% of votes. As CIBAC’s votes exceeded the initial 2% threshold by less than another full 2%, the COMELEC denied its claim for a second seat.
CIBAC, together with other party-list groups, filed a Joint Motion for Proclamation, arguing for entitlement to an additional seat. They contended that the COMELEC should have applied the formula established by the Supreme Court in Veterans Federation Party v. COMELEC and reiterated in Ang Bagong Bayani-OFW Labor Party v. COMELEC, which uses a proportional calculation. Under this judicial formula, CIBAC’s vote share would have yielded a fractional remainder potentially entitling it to an additional seat. The COMELEC en banc denied the motion through the assailed Resolution No. 06-0248, expressly adhering to its own simplified formula.

ISSUE

Whether the COMELEC committed grave abuse of discretion in denying CIBAC’s claim for an additional party-list seat by applying its simplified formula instead of the Veterans formula prescribed by the Supreme Court.

RULING

Yes, the COMELEC committed grave abuse of discretion. The Supreme Court annulled the portion of the COMELEC resolution that adopted and applied the simplified formula. The Court held that the COMELEC’s formula of “one additional seat per additional two percent” was a blatant disregard of settled jurisprudence and a violation of Republic Act No. 7941 (The Party-List System Act).
The legal logic is anchored on the principle of stare decisis and the constitutional mandate for the party-list system to promote proportional representation. The Veterans formula, which calculates additional seats by multiplying the party’s vote percentage by the number of seats allotted to the first party, is the governing rule established by the Court to give life to this proportional representation principle. The COMELEC, as an administrative body duty-bound to enforce election laws, cannot supplant this judicially ordained formula with its own simplified version. Its action constituted a capricious and whimsical exercise of power amounting to grave abuse of discretion. However, the Court ultimately denied CIBAC’s specific plea for a second seat because, upon applying the correct Veterans formula to the final vote count, CIBAC’s resulting quotient did not mathematically entitle it to an additional seat. The COMELEC was ordered to strictly apply the Veterans formula in all future determinations.