G.R. No. 37673 - People vs. Taneo

Submission and Content of the National Expenditures Program for Fiscal Year 2000

Pursuant to Section 22, Article VII of the Philippine Constitution, then President Joseph Ejercito Estrada submitted the National Expenditures Program for Fiscal Year 2000.
The Program proposed an Internal Revenue Allotment (IRA) of P121,778,000,000, calculated per the formula in Section 284 of the Local Government Code of 1991 which mandates LGUs to have a share in national internal revenue taxes based on collection of the third fiscal year preceding the current fiscal year, specifically:

On February 16, 2000, the President approved House Bill No. 8374, which became RA 8760, appropriating funds for the government for 2000.
Under Section XXXVII “Allocations to Local Government Units,” the IRA was set at P111,778,000,000 as Programmed Fund.
Separately, under Section LIV “Unprogrammed Fund,” an additional P10,000,000,000 was appropriated to fund the IRA but as Unprogrammed Fund, to be released only upon meeting certain revenue collection conditions assessed quarterly by specific committees (Development Budget Coordinating Committee, Senate Committee on Finance, House Committee on Appropriations).
The Unprogrammed Fund also had special provisions limiting release, including that it should only be released if revenue targets submitted by the President to Congress are achieved.

Petition for Certiorari, Prohibition and Mandamus Filed Before the Supreme Court

On August 22, 2000, various NGOs, people’s organizations, and barangay officials filed a petition against Executive Secretary Ronaldo Zamora, Secretary of Budget and Management Benjamin Diokno, National Treasurer Leonor Magtolis-Briones, and the Commission on Audit.
The petition challenged the constitutionality of the GAA provisions setting aside P10 Billion of the IRA as Unprogrammed Fund with conditional release dependent on revenue assessment.
Petitioners argued these provisions:

Violated the autonomy of LGUs and the constitutional mandate for automatic release of the IRA under Article X, Section 6 of the Constitution.
Contravened Sections 18, 284, and 286 of the Local Government Code.
Effectively placed a portion of the IRA under control of national government authorities, thus unlawfully reducing LGUs’ share.
Constituted undue delegation of legislative power and improper amendment of the Local Government Code through a GAA.

Both provinces filed motions to intervene, adopting and supporting the arguments of the petitioners.

Although the 2000 GAA’s effectivity had ceased, the Court proceeded to resolve the issues due to public interest and the possibility of recurring similar issues in future GAAs.
The Court cited precedent from The Province of Batangas v. Romulo emphasizing the justiciability of constitutional issues despite mootness or supervening events.

Whether the petition contains proper verifications and certifications against forum-shopping in compliance with procedural rules.
Whether petitioners have the legal standing to file the suit challenging the GAA provisions.
Whether the contested provisions in the 2000 GAA violate the constitutional mandate under Article X, Section 6 that the just share of LGUs in national taxes (IRA) shall be automatically released to them.