BANAT versus COMELEC Facts: On 27 June 2002, Barangay Association for National Advancement and Transparency (BANAT) filed

before the Commission on Elections (COMELEC) En Banc, acting as National Board of Canvassers (NBC) a Petition to Proclaim the Full Number of Party-List Representatives Provided by the Constitution. The cause of its petition is the COMELECs application of the Veterans Federation Party as COMELEC formula upon the completion of the canvass party-list results; thereby proclaiming 15 party-lists to have obtained 21 seats in Congress. COMELEC denied the petition for being moot and academic. Issue: How are the party list seats computed and allocated under the BANAT ruling as to the Veterans Ruling? Ruling: In the BANAT ruling, the procedure used to obtain the computation and allocation of the party lists guaranteed seats are as follows: First: The parties, organizations, and coalitions shall be ranked from the highest to the lowest based on the number of votes they garnered during the elections, Second: The parties, organizations, and coalitions receiving at least two percent (2%) of the total votes cast for the party-list system shall be entitled to one guaranteed seat each. Then, in the computation of additional seats, the following method is followed. Determination in the maximum seats for party list by .80 and .20 and then available seats and lastly additional seats. Thus, in the BANAT ruling, 2% guaranteed seat is calculated in proportion to their total number of votes while on the Veterans ruling, 2% is demanded for qualification for seat in the House of Representative calculated in proportion to the votes of the first party.