G.R. No. 246816 , September 15, 2020
Angkla: Ang Partido ng mga Pilipinong Marino, Inc. (Angkla), and Serbisyo sa Bayan Party (SBP), Petitioners, vs. Commission on Elections (Sitting as the National Board of Canvassers), et al., Respondents. Aksyon Magsasaka – Tinig Partido ng Masa (AKMA-PTM), Petitioner-in-Intervention.

FACTS

Petitioners Angkla, SBP, and AKMA-PTM assail COMELEC Resolution No. 004-19, which proclaimed the winning party-list groups from the May 2019 elections. The COMELEC, acting as the National Board of Canvassers, applied the seat allocation formula established in the Court’s 2009 decision in BANAT v. COMELEC. This resulted in the allocation of all 61 available party-list seats to only 51 groups, leaving petitioners without representation.
Petitioners argue the BANAT formula, as applied, violates the equal protection clause and the principle of “one voter, one party-list vote.” They specifically challenge the constitutionality of Section 11(b) of RA 7941 (Party-List System Act), contending it results in the double counting of votes for parties that surpass the 2% threshold. Petitioners propose an alternative formula where the 2% of votes used to earn a guaranteed seat for a party is first deducted from that party’s total vote count before the remaining votes are used in the proportional allocation of additional seats.

ISSUE

Did the COMELEC commit grave abuse of discretion in applying the BANAT formula for allocating party-list seats, and is Section 11(b) of RA 7941 unconstitutional for allegedly permitting double counting of votes?

RULING

No. The COMELEC did not commit grave abuse of discretion, and Section 11(b) of RA 7941 is constitutional. The petition essentially seeks a reinterpretation of the BANAT formula, which has been the settled doctrine governing party-list seat allocation for over a decade. The Court, in BANAT, explicitly rejected the method of deducting the 2% votes for the first seat before allocating additional seats. The ruling clarified that the total votes of a party are the basis for both the initial guaranteed seat (if the 2% threshold is met) and for the proportional allocation of additional seats. This is not double counting but a single counting of votes applied in a two-round allocation process to achieve the constitutional mandate of proportional representation.
The constitutional and statutory framework aims for a hybrid system that balances sectoral representation with proportional entitlement. The three-seat cap and the methodology approved in BANAT are designed to prevent any single group from dominating the party-list system, ensuring broad-based representation. The petitioners’ proposed formula would disproportionately diminish the voting strength of parties that have garnered significant popular support, thereby undermining the proportional component of the system. The COMELEC’s faithful application of the long-standing BANAT formula was a proper exercise of its ministerial duty as the National Board of Canvassers and was not tainted with grave abuse of discretion.