Title
Araullo vs. Aquino III
Case
G.R. No. 209287
Decision Date
Feb 3, 2015
Petitioners challenged the constitutionality of the Disbursement Acceleration Program (DAP), arguing it violated separation of powers and the President's limited authority to reallocate funds without Congressional approval. The Supreme Court ruled key DAP practices unconstitutional, emphasizing strict adherence to constitutional limits on executive power.
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Case Digest (G.R. No. 209287)

Facts:

  1. Parties Involved:

    • Petitioners: Various individuals, organizations, and representatives, including Maria Carolina P. Araullo, Judy M. Taguiwalo, Rep. Luz Ilagan, Rep. Terry L. Ridon, Rep. Carlos Isagani Zarate, Renato M. Reyes Jr., Manuel K. Dayrit, Vencer Mari E. Crisostomo, Victor Villanueva, Augusto L. Syjuco Jr., Manuelito R. Luna, Atty. Jose Malvar Villegas Jr., Philippine Constitution Association (PHILCONSA), Integrated Bar of the Philippines (IBP), Greco Antonious Beda B. Belgica, Bishop Reuben M. Abante, Rev. Jose L. Gonzalez, Confederation for Unity, Recognition and Advancement of Government Employees (COURAGE), and Volunteers Against Crime and Corruption (VACC).
    • Respondents: President Benigno Simeon C. Aquino III, Executive Secretary Paquito N. Ochoa Jr., and Secretary of the Department of Budget and Management (DBM) Florencio B. Abad.
  2. Subject Matter:
    The consolidated petitions challenge the constitutionality of the Disbursement Acceleration Program (DAP) and National Budget Circular (NBC) No. 541, which allowed the reallocation of savings and augmentation of funds for various government projects. Petitioners argue that the DAP violated the Constitution, particularly Section 25(5), Article VI, which governs the power of the President to augment appropriations.

  3. Key Allegations:

    • The DAP allowed the withdrawal of unobligated allotments and unreleased appropriations, which were declared as savings and used to fund projects not originally included in the General Appropriations Act (GAA).
    • Petitioners claimed that the DAP violated the principle of separation of powers, as it allowed the Executive to reallocate funds without Congressional approval.
    • They also argued that the DAP was used to fund projects that were not covered by any appropriation in the GAA, thereby violating the constitutional mandate that no money shall be paid out of the Treasury except in pursuance of an appropriation made by law.
  4. Procedural History:

    • The Supreme Court initially ruled on July 1, 2014, declaring certain acts and practices under the DAP unconstitutional.
    • Respondents filed a Motion for Reconsideration, arguing that the Court mischaracterized the issues and that the DAP was implemented in good faith to stimulate the economy.
    • Petitioners in G.R. No. 209442 filed a Motion for Partial Reconsideration, seeking a declaration that all funds used under the DAP for augmentation of items without actual deficiencies were unconstitutional.

Issue:

  1. Procedural Issues:

    • Whether the petitions presented an actual case or controversy, given that petitioners were not directly injured by the DAP.
    • Whether the petitioners had standing to bring the suits as citizens and taxpayers.
    • Whether the Court had jurisdiction to determine the constitutionality of the DAP and NBC No. 541.
  2. Substantive Issues:

    • Whether the withdrawal of unobligated allotments and unreleased appropriations under the DAP constituted "savings" as defined in the GAA.
    • Whether the President had the authority to transfer savings to other departments for augmentation purposes.
    • Whether the DAP violated Section 25(5), Article VI of the Constitution, which limits the President's power to augment appropriations.
    • Whether the use of Unprogrammed Funds to augment programmed appropriations was constitutional.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

The Supreme Court's decision in Araullo v. Aquino reaffirmed the principle that the Constitution is supreme and that all branches of government must operate within its limits. The Court's strict construction of the President's power to augment appropriations and its emphasis on the separation of powers serve as a reminder that even well-intentioned programs must comply with constitutional and legal requirements.


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