Sep 2, 2012

Coseteng v Mitra G.R. No. 86649 Digest

Coseteng v. Mitra (Digest)
G.R. No. 86649 July 12, 1990
Topic: Commission on Appointments

Facts:

1.          The congressional elections of May 11, 1987 resulted in the election to the House of the candidates of diverse political parties such as the PDP-Laban, Lakas ng Bansa (LB), Liberal Party (LP), NP-Unido, Kilusan ng Bagong Lipunan (KBL), Panaghiusa, Kababaihan Para sa Inang Bayan (KAIBA), and some independents. Petitioner Anna Dominique M.L. Coseteng was the only candidate elected under the banner of KAIBA.


2.           Then, House , upon nomination by the Majority Floor Leader, Cong. Francisco Sumulong, elected from the Coalesced Majority, eleven (11) out of twelve (12) congressmen to represent the House in the Commission on Appointments (CA).


3.         Upon nomination of the Minority Floor Leader, the House elected Honorable Roque Ablan, Jr., KBL, as the 12th CA member, representing the Coalesced Minority in the House.


4.            A year later, the LDP was organized as a political party. As 158 out of 202 members of the House affiliated with it the House committees, including the House representation in the CA, had to be reorganized to conform with the new political alignments.


5.      Petitioner Coseteng wrote a letter to Speaker Ramon Mitra requesting that as representative of KAIBA, she be appointed as a member of the CA and HRET. Her request was endorsed by nine (9) congressmen. After the reorganization, Congressman Ablan, KBL, was retained as the 12th member representing the House minority.


6.       Hence the petition of for Extraordinary legal writs by Coseteng to declare as null and void the election of respondent Ablan, Verano-Yap, Romero, Cuenco, Mercado, Bandon, Cabochan, Imperial, Lobregat, Beltran, Locsin, and Singson, as members of the Commission on Appointments, to enjoin them from acting as such and to enjoin also the other respondents from recognizing them as members of the Commission on Appointments on the theory that their election to that Commission violated the constitutional mandate of proportional representation on following grounds:


a.      the New Majority (158 LDP members out of the 202 members of the House) is entitled to only nine (9) seats out of the twelve to be filled by the House;

b.    the members representing the political parties, or coalitions thereof, must be nominated by their respective political parties or coalitions;

c.       the nomination and election of respondent Verano-Yap by the respondents as representative of the minority was clearly invalid; and

d.   that similarly invalid was the retention of respondent Ablan as Minority member in the Commission because he was neither nominated nor elected as such by the minority party or parties in the House.


7.        Petitioner Coseteng  further alleged that she is qualified to sit in the CA as a representative of the Minority because she has the support of nine (9) other congressmen and congresswomen of the Minority .


8.           Respondent’s contention was that: (1) that the legality of the reorganization of the CA is a political question, hence, outside the jurisdiction of this Court to decide, and (2) that in any case, the reorganization was "strictly in consonance with Section 18, Article VI of the 1987 Constitution" i.e., on the basis of proportional representation of the political parties, considering the majority coalition "as a form of a political party"


ISSUE: W/N the members of the House in the Commission on Appointments were chosen on the basis of proportional representation from the political parties therein as provided in Section 18, Article VI of the 1987 Constitution


YES.


1.       The Court held that the petition should be dismissed, not because it raises a political question, (which it does not), but because the revision of the House representation in the CA is based on proportional representation of the political parties therein as provided in Section 18, Article VI of the 1987 Constitution. Moreover, there is no merit in the petitioner's contention that the House members in the CA should have been nominated and elected by their respective political parties, as they were nominated by their respective floor leaders in the House. They were elected by the House (not by their party) in accordance with the Constitution. The validity of their election to the Commission on Appointments — eleven (11) from the Coalesced Majority and one from the minority — is unassailable.


2.            There are 160 members of the LDP in the House. They represent 79% of the House membership (which may be rounded out to 80%). Eighty percent (80%) of 12 members in the Commission on Appointments would equal 9.6 members, which may be rounded out to ten (10) members from the LDP. The remaining two seats were apportioned to the LP (respondent Lorna Verano-Yap) as the next largest party in the Coalesced Majority and the KBL (respondent Roque Ablan) as the principal opposition party in the House. There is no doubt that this apportionment of the House membership in the Commission on Appointments was done "on the basis of proportional representation of the political parties therein.


3.         The other political parties or groups in the House, such as petitioner's KAIBA (which is presumably a member also of the Coalesced Majority), are bound by the majority's choices. Even if KAIBA were to be considered as an opposition party, its lone member (petitioner Coseteng) represents only .4% or less than 1% of the House membership, hence, she is not entitled to one of the 12 House seats in the Commission on Appointments. To be able to claim proportional membership in the Commission on Appointments, a political party should represent at least 8.4% of the House membership, i.e., it should have been able to elect at least 17 congressmen or congresswomen.


4.      The indorsements of the nine (9) congressmen and congresswomen in favor of the petitioner's election to the Commission are inconsequential because they are not members of her party and they signed identical indorsements in favor of her rival, respondent Congresswoman Verano-Yap.

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