188 Chasing the Wind: Assessing Philippine Democracy, Second Edition CenPEG interview, the road of electoral reform does not end in Congress so that other channels can be used such as the judiciary and the parliament of the streets. Colmenares calls these the “3 Ks: Kongreso, Korte, Kalsada.” Rightly so, none of the 14 bills led in the Senate seeking to amend RA 7941 ever saw the light of day, either. Many of the Senate bills complement some of the House bills but notable were SB 168 (Sen. Loi Estrada) requiring that half of the PL nominees are women and SB 1904 (JV Ejercito) reserving PL seats solely for the marginalized and banning nominees with dynastic ties. One of the most contentious proposed amendments to the PL act led in both the lower House and Senate is on the seat cap. One side argued that retaining the seat cap prevents genuine representation since parties enjoying broad electoral support are limited to a maximum of three seats. Conversely, it was argued that doing away with the seat cap will only allow a single group with considerable electoral base to monopolize the PL system thus preventing smaller groups representing marginalized sectors from having a voice in Congress. Supreme Court: Inconsistent Rulings? Several of the petitions led before the SC on Party-list issues involved the disqualication or stopping the proclamation of certain PL groups. In doing so, the high court came up with a number of landmark decisions particularly on settling issues of proportional representation. One of these rulings sought to resolve once and for all the issue of lling up the 20% of seats earmarked for Party-list. Hence, in April 2009, the SC ordered the full implementation of the constitutional provision on the PL system, striking down as unconstitutional the 2% threshold in the allocation of seats. The 2% threshold combined with the 3-seat cap has prevented the complete lling up of the 20% of the House seats – or 55 in the current Congress – as mandated by the constitution. Accordingly, the ruling penned by Associate Justice Antonio Carpio, shot down the old formula, “First Party Rule,” as cited in the Veterans Federation, Inc. vs Comelec case which granted only the maximum three seats to the party-list group that garnered the highest votes in the party-list elections. In revising its own decision the SC ruled that the 2% threshold only “guarantees a seat to the two percenters” but does not limit them to only one seat. The Carpio formula does not limit the maximum three seats only to the highest party-list vote-getter. Moreover, the same formula also distributes the seats even to those groups that do not meet the 2% threshold in order to ensure the full implementation of the 20% seats for Party-list in the lower House. However, this same formula has also led to the further fragmentation of the PL system as an increasing number of groups with smaller electoral constituencies (smaller than 2% of the total votes cast for the PL system) can now be awarded legislative seats.