Angkla v. Comelec: Seat Allocation Ruling
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Pinky Rose Dela CruzAngkla v. Comelec: Seat Allocation Ruling
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Powered by AIThe Court upheld NBOC Resolution No. 004-19 because the petitioners failed to satisfy the third requisite for judicial review, which requires the question of constitutionality to be raised at the earliest possible opportunity. Furthermore, in prior elections, the petitioners had benefited from the BANAT doctrine, which they were now contesting. This inconsistency weakened their case, resulting in the Court's decision to maintain the resolution .
Previous participation in elections influenced the petitioners' legal standing negatively because they had accepted and benefited from the BANAT formula, which they now challenged. This past acceptance weakened their argument that the seat allocation was unconstitutional, as they had supported it in previous instances, thus reducing the credibility and consistency of their current claims .
The legal grounds for the Court's decision to deem Section 11(b) of RA 7941 constitutional included the lack of a timely constitutional question and the consistency with the existing legal precedent set by the BANAT case. The Court did not find any grave abuse of discretion that infringed upon constitutional norms, and hence, upheld the existing methodology as not unconstitutional .
The equal protection clause was central to the petitioners' arguments against the current party-list seat allocation process as they claimed that it led to an unconstitutional double-counting of votes, skewing outcomes in favor of the two-percenters. This allegedly granted an undue advantage by considering the same votes both for securing initial representation and for calculating additional seats, thus violating the principle of equal protection under the law .
Article VIII of the Constitution relates to this case as it confers the power of judicial review to the judicial branch of government. This power allows the courts to nullify actions of any government branch, including legislative actions, if they infringe upon the Constitution through grave abuse of discretion. Even though the petitioners sought to use this provision, the Court did not find sufficient grounds to determine that Section 11(b) of RA 7941 was unconstitutional under this power .
The BANAT formula served as a basis for the allocation of party-list seats under Section 11(b) of RA 7941. The court's decision referenced this formula as a legally upheld method for distributing additional seats proportionally. The petitioners themselves had previously benefited from this formula in earlier elections, which undermined their current objections and reinforced the Court's decision to uphold the allocation methodology confirmed in NBOC Resolution No. 004-19 .
The timing of the petition affected the Court's decision because the question of constitutionality was not raised at the earliest possible opportunity. According to the third requisite for judicial review, such issues must be timely presented to be considered. Since the petitioners brought up their objections only after previously benefiting from the same legal doctrine (BANAT), the Court viewed this delay as detrimental to their case, leading to the upholding of NBOC Resolution No. 004-19 .
Petitioners ANGKLA and SBP argued that Section 11(b) of RA 7941 was unconstitutional because it allowed for double-counting of votes in favor of the 'two-percenters,' violating the equal protection clause. They contended that the same votes used to secure a seat in the first round of allocation were again considered in the allocation of additional seats, creating an unfair advantage .
The main constitutional issue in the case was whether Section 11(b) of RA 7941, which allocates additional party-list seats in proportion to their total number of votes, was unconstitutional. The petitioners argued that this allocation method resulted in double-counting of votes in favor of the two-percenters and violated the equal protection clause. However, the Court ruled that Section 11(b) was not unconstitutional and upheld the existing seat allocation method set forth by the National Board of Canvassers .
The Court relied on the precedent set in the BANAT case while evaluating the constitutionality of the seat allocation method. This precedent endorsed the method used for allocating party-list seats, which the petitioners initially benefited from in previous elections. The Court found no sufficient basis for overturning the ruling established in BANAT when assessing the petitions from ANGKLA and SBP .
![[ G.R. No. 246816, September 15, 2020 ]
ANGKLA: ANG PARTIDO NG MGA PILIPINONG MARINO, INC.
(ANGKLA), AND SERBISYO SA BAYAN PA](/p?url=https%3A%2F%2Fscreenshots.scribd.com%2FScribd%2F252_100_85%2F415%2F514817136%2F1.jpeg&__src=https%3A%2F%2Fwww.scribd.com%2Fdocument%2F514817136%2FPolitical-Law-1&__type=image)
