Case Digest (G.R. No. 166715) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Abakada Guro Party List v. Purisima (G.R. No. 166715, August 14, 2008), petitioners Advocates and Adherents of Social Justice for School Teachers and Allied Workers, represented by officers Samson S. Alcantara, Ed Vincent S. Albano, Romeo R. Robiso, Rene B. Gorospe and Edwin R. Sandoval, filed a petition for prohibition under Rule 65 of the Rules of Court to enjoin respondents Secretary Cesar V. Purisima (Department of Finance), Commissioner Guillermo L. Parayno, Jr. (Bureau of Internal Revenue) and Commissioner Alberto D. Lina (Bureau of Customs) from implementing and enforcing Republic Act No. 9335 (Attrition Act of 2005). Enacted to optimize revenue generation by encouraging BIR and BOC officials and employees to exceed targets, RA 9335 created a Rewards and Incentives Fund, a Revenue Performance Evaluation Board in each bureau and a Joint Congressional Oversight Committee to approve the Implementing Rules and Regulations (IRR). The petitioners, as taxpayers, claimed that Case Digest (G.R. No. 166715) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Nature of Action
- Petitioners: Abakada Guro Party List officers/members (Alcantara, Albano, Robiso, Gorospe, Sandoval).
- Respondents: Secretary of Finance Purisima; BIR Commissioner Parayno; BOC Commissioner Lina.
- Relief Sought: Prohibition to prevent implementation and enforcement of Republic Act No. 9335 (Attrition Act of 2005).
- Key Features of RA 9335
- Objective: Optimize revenue collection of the Bureau of Internal Revenue (BIR) and Bureau of Customs (BOC) via a system of rewards and sanctions.
- Coverage: All BIR and BOC officials/employees with at least six months’ service.
- Rewards and Incentives Fund (Fund):
- Fund sourced from collections exceeding revenue targets as determined by the Development Budget and Coordinating Committee (DBCC).
- Allocation proportionate to each bureau’s contribution to excess collections.
- Revenue Performance Evaluation Boards (Boards):
- Composition: Secretary/Undersecretary of Finance; Secretary/Undersecretary of Budget and Management; Director General/Deputy Director General of NEDA; Commissioners/Deputy Commissioners of BIR and BOC; two rank‐and‐file representatives; one official representative.
- Functions:
- Prescribe rules for Fund allocation, distribution, release.
- Set criteria/procedures for removal of under‐performing personnel.
- Terminate personnel per criteria.
- Prescribe performance evaluation system.
- Issue implementing rules and regulations (IRR).
- Submit annual report to Congress.
- Implementing Rules and Regulations: DOF, DBM, NEDA, BIR, BOC, CSC to draft IRR; approval by Joint Congressional Oversight Committee.
- Petitioners’ Contentions
- Rewards system reduces public servants to “mercenaries,” invites corruption, and undermines fiduciary duty of public officers.
- Equal Protection Violation: Classification limited to BIR/BOC employees lacks rational basis compared to other government personnel.
- Undue Delegation: Presidential power to fix revenue targets lacks sufficient standards, threatening arbitrary or unattainable targets leading to dismissals.
- Separation of Powers Violation: Congressional Oversight Committee’s role in approving IRR entangles legislature in executive enforcement.
- Respondents’ Position
- Petition is premature—no actual case or controversy or personal adverse effect.
- On merits:
- Reward system rests on presumption of regularity of public officers; not speculative.
- Classification is rational—BIR and BOC share distinct revenue‐collection functions.
- Delegation contains sufficient standards (Sections 2, 4, 5, 7 of RA 9335).
- Oversight committee reinforces checks and balances; does not violate separation of powers.
Issues:
- Justiciability
- Does an actual case or controversy exist?
- Is the petition ripe for adjudication?
- Constitutionality of RA 9335 Provisions
- Does the rewards and sanctions scheme breach the accountability requirement of public office?
- Does the classification of beneficiaries under the equal protection clause lack a rational basis?
- Does delegation of authority to fix revenue targets to the President constitute undue legislative delegation?
- Does Section 12’s Joint Congressional Oversight Committee violate the separation of powers (bicameralism, presentment, and nondelegation principles)?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)