Daza Vs Luis Singson

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Raul Daza vs Luis Singson

Tribunal and its Composition

The Laban ng Demokratikong Pilipino (LDP) was reorganized resulting to a political realignment in the
lower house. LDP also changed its representation in the Commission on Appointments. They withdrew the
seat occupied by Daza (LDP member) and gave it to the new LDP member. Thereafter the chamber elected
a new set of representatives in the CoA which consisted of the original members except Daza who was
replaced by Singson. Daza questioned such replacement.

ISSUE: Whether or not a change resulting from a political realignment validly changes the composition of
the Commission on Appointments.

HELD: As provided in the constitution, there should be a Commission on Appointments consisting of


twelve Senators and twelve members of the House of Representatives elected by each House respectively
on the basis of proportional representation of the political parties therein, this necessarily connotes the
authority of each house of Congress to see to it that the requirement is duly complied with. Therefore, it
may take appropriate measures, not only upon the initial organization of the Commission but also
subsequently thereto NOT the court.

Daza V. Singson
Case
Daza was chosen to be part of the Commission of Appointments and was listed as representative of the
Liberal Party. LDP was reorganized and 24 members from the Liberal Party transferred to LDP. Because
of this, the House of Representatives revised its representation by withdrawing the seat given to Daza and
giving it to the newly-formed LDP. Singson was chosen to replace Daza, in accordance to proportional
representation.
Issues
1. Whether the reorganized LDP can be deemed a stable political party

2. Whether it is necessary for the party to be registered to be entitled to proportional representation


in the CA

Held and Ratio


Both petitioner and respondent invoke the case of Cunanan v. Tan. In the said case, 25 Members of the
Nacionalista Party reorganized themselves and formed the Allied Majority. 3 Nacionalista Congressmen,
originally chosen, were deprived of their seats by colleagues who joined the Allied Majority. Carlos
Cunanans ad interim appointment was rejected by the CA. Jorge Tan was designated in his place.
Cunanan contended the validity of the rejection. The Court agreed that Allied Majority was merely a
temporary combination; officially, they were still part of the Nacionalista Party. Thus, the reorganization
of the CA at that time was not based on proportional representation. The Court held that mere shift of
votes should not affect the organization of the CA, or else, it would forever be at the mercy of the House
of Representatives.
The petitioner argues that LDP is not a permanent party and has not yet achieved stability. However, the
LDP has already been in existence for a year. They command the biggest following. They not only
survived but prevailed.
Regarding being a duly registered party, the LDP was granted its registration as a political party by the
COMELEC. Thus, shattering the argument of the petitioner that registration is required.

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