G.R. No. 86649 July 12, 1990
Anna Dominique M.L. Coseteng and Kababaihan Para Sa Inang Bayan, petitioners, vs. Hon. Ramon V. Mitra, Jr., as Speaker of the House of Representatives, et al., respondents.

FACTS

Following the 1987 congressional elections, the House of Representatives elected eleven members from the Coalesced Majority and one from the Coalesced Minority to the Commission on Appointments. A year later, the Laban ng Demokratikong Pilipino (LDP) was organized, with 158 House members affiliating, necessitating a reorganization of House committees and its representation in the Commission. On December 5, 1988, the House revised its majority membership in the Commission, replacing one member with an LDP representative. Petitioner Anna Dominique Coseteng, the lone elected representative of the Kababaihan Para sa Inang Bayan (KAIBA), requested appointment to the Commission, endorsed by nine congressmen. Her request was not granted.
Petitioner Coseteng and KAIBA filed a petition, essentially for quo warranto and injunction, seeking to nullify the election of the respondents to the Commission on Appointments. They alleged the election violated the constitutional mandate of proportional representation, arguing the new LDP majority was entitled to only nine seats, that members must be nominated by their respective political parties, and that the selection of the minority representative was invalid. Coseteng claimed qualification to represent the minority.

ISSUE

Whether the election of the respondents as members of the Commission on Appointments by the House of Representatives violated Section 18, Article VI of the 1987 Constitution on proportional representation.

RULING

The Supreme Court dismissed the petition. The Court first held the issue was justiciable, not a political question, as it involved the interpretation and application of a constitutional provision. On the merits, the Court found the House’s composition of its Commission membership was based on proportional representation. The LDP, with 160 members (79% of the House), was entitled to roughly 80% of the 12 seats, equating to 9.6 members, which could be rounded to ten. The remaining two seats were properly apportioned to the Liberal Party (as the next largest party in the majority coalition) and the Kilusang Bagong Lipunan (as the principal opposition party). This allocation satisfied the constitutional requirement.
The Court rejected the petitioner’s claim for a seat. Even if KAIBA were considered part of the opposition, its single member represented less than 1% of the House. To claim proportional membership, a party must represent at least 8.4% of the House, requiring at least 17 members. The endorsements from nine congressmen for Coseteng were inconsequential, as they were not members of her party and had signed identical endorsements for another candidate. The Court also ruled that the Constitution does not require nomination by political parties; nomination by floor leaders and election by the entire House is sufficient. The election was valid.