G.R. No. 180055 & G.R. No. 183055; July 31, 2009
Franklin M. Drilon, et al. vs. Hon. Jose De Venecia Jr., et al. / Senator Ma. Ana Consuelo A.S. Madrigal vs. Senator Manuel Villar, et al.

FACTS

In August 2007, both houses of Congress elected their respective contingents to the Commission on Appointments (CA). The Liberal Party (LP), with at least 20 members in the House of Representatives, sought representation in the House contingent to the CA. Petitioners, led by Franklin Drilon, formally requested then-Speaker Jose de Venecia and the House leadership for one seat, invoking the constitutional mandate for proportional representation. The House Legal Department undertook a study but had not released an opinion, prompting the LP to file a petition for prohibition, mandamus, and quo warranto ( G.R. No. 180055 ). They argued the House contingent’s composition violated Section 18, Article VI of the Constitution by excluding the LP.
In a separate but related petition (G.R. No. 183055), Senator Ma. Ana Consuelo Madrigal challenged the Senate’s election of its CA members. She contended that the election was invalid for failing to comply with the constitutional requirement that the CA be composed of twelve Senators and twelve House members, elected based on proportional representation from political parties. She argued the Senate’s election of only eleven members and the inclusion of senators whose party affiliations were allegedly misrepresented contravened this rule.

ISSUE

The core issue, consolidated across both petitions, is whether the Supreme Court can compel Congress to reconstitute the Commission on Appointments for alleged non-compliance with the constitutional rule on proportional representation of political parties.

RULING

The Supreme Court dismissed both petitions. For G.R. No. 180055 , the petition was withdrawn upon motion by the petitioners. For G.R. No. 183055, the Court ruled it could not grant the relief sought. The Court emphasized the doctrine of separation of powers and the principle of respect for co-equal departments. The Constitution vests in each house of Congress the exclusive authority to elect its members to the CA. This power is discretionary and not subject to judicial mandamus.
The Court clarified that while Section 18, Article VI of the Constitution provides the rule of proportional representation, the actual determination of party affiliation and the allocation of seats based thereon is a political question best left to the sound discretion of the legislative body. The judiciary cannot interfere with or dictate the outcome of this internal legislative process. Senator Madrigal’s petition was deemed premature, as her concerns were still being addressed within the Senate. Furthermore, her suggestions regarding specific senators’ party affiliations involved factual determinations outside the Court’s province. The Court held that the composition of the CA, being a product of the exercise of congressional prerogative, enjoys a presumption of regularity and conformity with constitutional requirements.