The correct and prevailing formula for computing additional seats for qualified party-list groups is the one established in Veterans Federation Party v. COMELEC, which is: (Number of votes of concerned party / Number of votes of first party) x Number of additional seats allocated to the first party. A party-list group must obtain an exact whole number in this computation to be entitled to an additional seat; fractions are not rounded up.

The dispute arose from the allocation of party-list seats in the House of Representatives following the May 2004 National and Local Elections. After petitioner CIBAC was proclaimed as having qualified for one seat by receiving the required two percent (2%) of the total votes cast for party-list representatives, a controversy emerged regarding its entitlement to an additional seat, hinging on the correct formula for computation to be used by the COMELEC.

• The COMELEC, in Resolution No. NBC 04-004 (June 2, 2004), proclaimed petitioner CIBAC as qualified for one seat in Congress, having received 493,546 votes (3.9084%) out of 12,627,852 total party-list votes in the May 2004 elections.
• For computing additional seats, the COMELEC, in its Resolution No. 6835 (May 8, 2004), adopted a "simplified formula" of one additional seat per additional 2% of total party-list votes. This formula did not grant CIBAC an additional seat.
• CIBAC, with BUTIL and PM, filed a Joint Motion for Immediate Proclamation, claiming entitlement to an additional seat based on their interpretation of the formula from Ang Bagong Bayani and Bayan Muna, using "allotted seats for the first party" as the multiplier.
• On March 7, 2006, COMELEC issued Resolution No. 06-0248, denying the motion and upholding its "simplified formula," stating CIBAC (with 3.8638% per COMELEC memo) was not entitled to an additional seat after deducting the initial 2%.
• The first party, Bayan Muna, garnered 1,203,305 votes and was entitled to the maximum three seats. CIBAC's vote count used in the Supreme Court's critical computations was 495,190.

• The COMELEC committed grave abuse of discretion by using its "simplified formula" instead of the formula allegedly established in Ang Bagong Bayani and Bayan Muna.
• The correct multiplier, based on Ang Bagong Bayani and Bayan Muna, should be the "allotted seats for the first party" (which was 3 for Bayan Muna), which would entitle CIBAC to an additional seat (495,193 / 1,203,305 x 3 = 1.2345).
• The Ang Bagong Bayani and Bayan Muna formula effectively modified the earlier Veterans formula regarding the multiplier.
• The COMELEC's failure to resolve disqualification petitions against other party-list groups hindered an accurate determination of votes.

• The COMELEC correctly applied its "simplified formula" of one additional seat per additional two percent of total party-list votes, as per COMELEC Resolution No. 6835.
• Under this simplified formula, CIBAC was not entitled to an additional seat after the first 2% of its votes was deducted.
• The COMELEC contended that the formula in Veterans used "the [number] of additional seats allocated to the first party" as the multiplier, which differed from the "allotted seats for first party" multiplier CIBAC claimed from Ang Bagong Bayani and Bayan Muna.
• The COMELEC's Resolution No. 6835 was based on a Supreme Court Resolution (November 20, 2003, in G.R. Nos. 147589 & 147613 regarding BUHAY) which allegedly recognized the simplified formula.

• Whether the COMELEC committed grave abuse of discretion in adopting its "simplified formula" (one additional seat per additional 2% of total party-list votes) and thereby denying CIBAC an additional seat.
• Whether CIBAC is entitled to an additional party-list seat based on the formula it claims was established in Ang Bagong Bayani and Bayan Muna.
• What is the correct and prevailing formula for determining the entitlement of qualified party-list groups to additional seats in the House of Representatives?

• The petition was DENIED. The Supreme Court affirmed that CIBAC was not entitled to an additional seat.
• The portion of COMELEC Resolution No. 06-0248 adopting and applying the "simplified formula of the Commission on the matter per Comelec Resolution No. 6835" was ANNULLED and SET ASIDE.
• The Court reiterated that the correct formula for computing additional seats for qualified party-list groups (other than the first party) is the one established in Veterans Federation Party v. COMELEC: Additional Seats = (Number of votes of concerned party / Number of votes of first party) x Number of additional seats allocated to the first party.
• The Court clarified that the Ang Bagong Bayani and Bayan Muna case did not modify the Veterans formula; the use of "allotted seats for the first party" as a multiplier in Ang Bagong Bayani was an inaccurate presentation due to the inadvertent omission of "[number] of additional."
• Applying the correct Veterans formula, CIBAC's computation is (495,190 votes / 1,203,305 votes for Bayan Muna) x 2 (additional seats for Bayan Muna, which received 3 total seats) = 0.82304986.
• Since 0.82304986 is less than one, and the Veterans case requires an "exact whole number" to be entitled to an additional seat, CIBAC is not entitled to an additional seat.
• The COMELEC was ORDERED to strictly apply the Veterans formula in determining additional party-list seats. The Supreme Court Resolution of November 20, 2003, concerning BUHAY, was deemed pro hac vice and not a precedent.

• Proportional Representation in Party-List System — A principle mandated by R.A. 7941 and the Constitution ensuring that legislative representation reflects the votes received by parties. The Court held that the Veterans formula is the method to achieve this proportional representation for additional party-list seats, within statutory limits like the three-seat cap.
• Four Inviolable Parameters for Party-List Elections (from Veterans) — These are: (1) the 20% allocation of House seats for party-lists; (2) the 2% vote threshold for a party to earn one seat; (3) the three-seat limit per party; and (4) proportional representation for additional seats. The Court applied these parameters to frame the discussion, emphasizing that the computation of additional seats must align with the fourth parameter using the Veterans formula.
• Veterans Formula for Additional Seats — For parties other than the first, Additional Seats = (No. of votes of concerned party / No. of votes of first party) x No. of additional seats allocated to the first party. This formula was identified and applied by the Court as the correct and sole method for calculating CIBAC's (and other qualified parties') entitlement to additional seats, leading to the conclusion that CIBAC was not entitled to one.
• Requirement of Exact Whole Number for Additional Seat (from Veterans) — A party-list organization must obtain a result of at least one whole integer in the computation for additional seats to be entitled to an additional seat; fractions are not rounded up or down. This was applied to CIBAC's resulting computation of 0.82304986, which, being less than one, disqualified it from an additional seat.
• Judicial Hierarchy and Stare Decisis — The principle that lower courts and quasi-judicial bodies are bound by the decisions of the highest court. The Supreme Court admonished the COMELEC for failing to adhere to the established Veterans formula and instead using its own "simplified formula" or misinterpreting Supreme Court resolutions, emphasizing that COMELEC must follow Supreme Court rulings.
• Pro Hac Vice Ruling — A judicial ruling made "for this one particular occasion" and not intended as binding precedent for future cases. The Court categorized its November 20, 2003 Resolution (granting BUHAY an additional seat), which COMELEC cited, as pro hac vice, meaning it did not establish a new general rule or modify the Veterans formula.

• "In determining the number of additional seats for each party-list that has met the 2% threshold, 'proportional representation' is the touchstone to ascertain entitlement to extra seats."
• "The above formula does not give an exact mathematical representation of the number of additional seats to be awarded since, in order to be entitled to one additional seat, an exact whole number is necessary."
• "It is apparent that the phrase '[number] of additional' was omitted, possibly by inadvertence from the phrase 'allotted seats for First Party.' The disparity is material, substantial, and significant since the multiplier '[number] of additional seats allocated to the First Party' prescribed in the Veterans formula pertains to a multiplier of two (2) seats, while the multiplier 'allotted seats for the first party' in Ang Bagong Bayani and Bayan Muna formula can mean a multiplier of maximum three (3) seats, since the first party can garner a maximum of three (3) seats."
• "As judicial decisions form part of the law of the land, the COMELEC cannot just ignore or be oblivious to the rulings issued by the Court. Basic is the rule that lower courts and quasi-judicial tribunals must bow to the decisions and resolutions of the highest court of the land. The COMELEC is not an exception. It cannot do otherwise."

• Veterans Federation Party v. COMELEC (G.R. Nos. 136781, 136786, & 136795, October 6, 2000) — Referenced as the landmark decision that established the four inviolable parameters for party-list seat allocation and the definitive formula for computing additional seats, which the Court in this case affirmed and ordered to be strictly followed.
• Ang Bagong Bayani-OFW Labor Party v. COMELEC (G.R. Nos. 147589 & 147613, June 25, 2003) — Cited by petitioner CIBAC as purportedly modifying the Veterans formula. The Supreme Court clarified that this case did not alter the Veterans formula but contained an "inaccurate presentation" of it regarding the multiplier for additional seats due to an omission.
• Partido ng Manggagawa v. COMELEC (G.R. No. 164702, March 15, 2006) — Referenced by the Court to show it had previously acknowledged confusion arising from the citation of the Veterans formula in the Ang Bagong Bayani resolution and had already reiterated that the Veterans formula remains the prevailing standard.
• Ang Bagong Bayani, OFW v. COMELEC (G.R. Nos. 147589 & 147613, November 20, 2003) — Cited by COMELEC as a basis for its "simplified formula." The Supreme Court clarified that its resolution in this specific instance (granting BUHAY an additional seat) was applied pro hac vice and did not set a new precedent or abandon the Veterans formula.

• Republic Act No. 7941 (Party-List System Act), Section 2 (Declaration of Policy) — Cited to underscore the state's objective to promote proportional representation, enable marginalized sectors' participation in legislation, and provide the "simplest scheme possible" for party-list elections. The Court's ruling aimed to align with these policy objectives by clarifying the correct proportional representation formula.
• Republic Act No. 7941 (Party-List System Act), Section 11 (Number of Party-List Representatives) — Cited as the statutory basis for allocating party-list seats, stipulating one seat for parties getting at least 2% of votes, additional seats "in proportion to their total number of votes" for those exceeding 2%, and a three-seat maximum per party. The entire case revolved around the correct interpretation and application of this provision for additional seats.
• Rules of Court, Rule 65 (Certiorari, Prohibition and Mandamus) — Mentioned as the procedural remedy availed of by CIBAC to bring its case before the Supreme Court, alleging grave abuse of discretion by the COMELEC.