Case Digest (G.R. No. 264958)
Facts:
On January 13, 2014, Greco Antonious Beda Belgica filed a petition under Rule 65, seeking certiorari and prohibition to enjoin the release and disbursement of certain lump-sum discretionary funds in Republic Act No. 10633 (the 2014 General Appropriations Act or 2014 GAA). Belgica challenged the constitutionality of the Unprogrammed Fund, the Contingent Fund, the E-Government Fund, and the Local Government Support Fund on the ground that they replicate the Priority Development Assistance Fund (PDAF) scheme struck down in Belgica v. Ochoa, Jr. (721 Phil. 416 [2013]). The petitioners alleged that these lump-sum appropriations violate (a) the doctrine on non-delegability of legislative power; (b) the separation of powers by depriving the President of his line-item veto; and (c) the requirements for a valid appropriation under the 1987 Constitution, the Administrative Code of 1987, and presidential line-item rules. Respondents, represented by the Office of the Solicitor General, cCase Digest (G.R. No. 264958)
Facts:
- Belgica I decision and its aftermath
- On November 19, 2013, the Court in Belgica v. Ochoa, Jr. (2013 Belgica case) struck down the 2013 PDAF article and similar pork-barrel provisions for violating separation of powers, non-delegability, and the President’s line-item veto.
- The Court articulated the “rule on singular correspondence”: an appropriation must be a line-item (a specific amount for a specific purpose), and lump-sum appropriations for multiple purposes requiring post-enactment determination are unconstitutional.
- The 2014 General Appropriations Act and the petition
- Republic Act 10633 (2014 GAA), enacted December 27, 2013, appropriated funds, including lump-sum discretionary funds: Unprogrammed Fund, Contingent Fund, E-Government Fund, and Local Government Support Fund.
- On January 13, 2014, petitioner Belgica filed a petition for certiorari and prohibition to declare these lump-sum funds unconstitutional, securing a status quo ante order.
Issues:
- Constitutionality of lump-sum discretionary funds under the 2014 GAA
- Do these appropriations violate the doctrine of non-delegability of legislative power (insufficient standards)?
- Do they impair the essence of separation of powers and the President’s line-item veto?
- Validity of appropriation and compliance with administrative rules
- Do the funds lack the requirements of a valid appropriation (specific purposes and amounts)?
- Do they comply with the form, content, and preparation requirements under Executive Order No. 292 (Administrative Code)?
- Justiciability and procedural questions
- Is there an actual case or controversy and standing?
- Is the petition moot given the lapse of fiscal year 2014?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)