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.