Constitutional Law
Daza v. Singson
G.R. No. 86344: December 21, 1989
FACTS:
The House of Representatives proportionally apportioned its 12 seats in the
Commission on Appointments among the political parties represented in the said chamber, in
accordance with Section 18, Article VI, of the 1987 Constitution. Petitioner Representative
Raul Daza was selected as the representative of the Liberal Party.
On September 16, 1988, twenty-four members of the Liberal Party joined the Laban
ng Demokratikong Pilipino Party, thus increasing its membership to 159, while the Liberal
Party was left with only 17 members. As a result, the House of Representatives revised its
representation in the Commission on Appointments, thereby removing Daza. Respondent
Representative Luis Singson replaced him.
Petitioner contends that he cannot be removed from the Commission on
Appointments because under Cunanan v. Tan, the reorganization of a political party must be
permanent and such political party must be a duly registered political party that has attained
political stability. He alleges that the LDP has not yet attained such status.
On the other hand, respondent Luis Singson alleges that the issue is a political
question and thus the Supreme Court has no jurisdiction over it.
ISSUES:
I. May the Electoral Tribunal be reorganized?
II. Whether or not the Supreme Court has jurisdiction over the case at bar
RULING:
I. YES. According to the Supreme Court, the House of Representatives has the
authority “to change its representation in the Commission on Appointments to reflect at any
time the changes that may transpire in the political alignments of its membership. It is
understood that such changes must be permanent and do not include the temporary alliances
or factional divisions not involving severance of political loyalties or formal disaffiliation and
permanent shifts of allegiance from one political party to another.” The case at bar is unlike
Cunanan because the Laban ng Demokratikong Pilipino Party is a duly registered political
party. And, if the petitioner’s contention that the Laban ng Demokratikong Pilipino Party has
not yet been tested by time is to be followed, then virtually all the members of all parties
except the Liberal Party and even the independent politicians would not qualify to become a
member of the Commission on Appointments.
II. Even political questions are subject to judicial reviews under the expanded
jurisdiction conferred upon the Courts by Section 1, Article VIII, of the 1987 Constitution:
“Judicial power includes the duty of the courts of justice to settle actual controversies
involving rights which are legally demandable and enforceable, and to determine whether or
not there has been a grave abuse of discretion amounting to lack or excess of jurisdiction on
the part of any branch or instrumentality of the Government.”