Daza V.

Singson A133
G.R. No. 86344 Commission on Appointments
December 21, 1989
Cruz, J.
Provisions
< Article VI, Section 18 of the 1987 Constitution- Comm on App, 12 Sen, 12 of HOR, basis of
proportional rep from pol parties/orgs under party-list system
Facts
< Raul Daza- Member of Liberal Party (LP). After congressional elections in May 1987, he was
among chosen in CommApp as representative of his party-list (in accordance to proportional
representation requirement in the Constitution)
< Luis Singson- Member of Laban ng Demokratikong Pilipino (LDP)
< In September 1988, LDP reorganized, which resulted in a political realignment in the House of
Representatives (HoR).
/ 24 LP members resigned and joined LDP (Membership count now: LDP = 159; LP = 17)
< As a result, HoR revised its representation in CommApp by withdrawing Daza’s seat and gave it
to LDP.
< December 1988: chamber elected new set of representatives consisting of original members
except Daza and including Singson as additional member from the LDP
Petitioner
< Reorganization of House representation is not based on a permanent political realignment.
< LDP is not a duly registered political party (under Art. IX-B, Sec. 2(5)).
< LDP has not attained political stability. : LDP must stil pass the test of time, which means no
entitlement to representation if party is organized recently and has not yet “aged.”
< LDP must survive in general congressional election.
Respondent’s arguments:
< Petitioner raised a pol. question and is beyond Court jurisdiction.
< Nowhere in the Constitution says that the political party must be registered to be entitled to
CommApp’s proportional representation.

Cunanan v. Tan (past case, cited by both parties)

< Petitioner: His election is permanent acc. to doctrine in Cunanan v. Tan.
< Respondent: Reorganization can change pol. allignments as long as changes are permanent
< Case: Nacionalista: 72 seats won in HOR, Liberal: 29, Independent: 1
/ Representation appropriated to: 8 members from NP and 4 from LP
 / But 25 members of Nacionalista Party expressed discontent over House leadership, made
common cause with LP, and formed the “Allied Majority” to install new Speaker and reorganize
the chamber.
/ Reorganization: 3 Nacionalista congressmen were displaced by 3 of their colleagues from Allied
Majority
/ Cunanan’s appointment as Deputy Administrator of the Reforestration Administration was
rejected by CommApp, so he came to Court, contending that his rejection was null and
void because CommApp itself was invalidly constituted.
/ Court agreed with Cunanan and said Allied Majority was a merely temporary combination.
Official y, the members of Allied Majority from Nacionalista are stil part of the latter party.
Reorganization is invalid because it was not based on proportional representation as required
by Consti.

Issues:
1. W/N court has jurisdiction- YES
< Matter is not a discretionary act of HoR. What is involved is the legality and not the wisdom of
the act.
/ The Court held here that the petitioners were questioning the manner of fil ing Tribunal and
not the discretion of the Senate. This is a justiciable and not a political question.
2. W/N Daza was unlawfully removed from his seat in the Commission on Appointments – NO
< House of Congress is clothed with full authority to declare vacant the necessary number of
seats in the CommApp (held by members of Congress belonging to the political party affected
by change) and then fil said vacancies according to Constitution.
< In November 1989, argument that LDP not registered became moot
/ COMELEC granted petition of LDP for registration as a political party.
< On LDP must stil pass the test of time, which means no representation if party is organized
recently and has not yet “aged”
/ Even LP would fall under such category. When LP supported Manual Roxas and LP won, no one
questioned to its CommApp representation even though LP was only 4 months old.
< HOR can change its representation anytime the changes that may transpire in political alignments
of its membership, but changes must be permanent
< It is noteworthy that LP did not object when they were allotted 2 seats when their
membership is at 41. But now that its membership has been cut by more than half, it opposed
withdrawal of 1 seat.
Dispositive: Petition DISMISSED. Temporary restraining order LIFTED. Respondent is validly elected and
is entitled to resume his seat pursuant to Art. VI, Sec. 18 of the Constitution.