G.R. No. 148306 - Reforzado vs. Spouses Lopez

Petitioners: Hon. Jonathan A. Dela Cruz and Hon. Gustavo S. Tambunting, Members of the House of Representatives and taxpayers.
Respondents: Hon. Paquito N. Ochoa Jr. (Executive Secretary), Hon. Joseph Emilio A. Abaya (Secretary, Department of Transportation and Communications - DOTC), Hon. Florencio B. Abad (Secretary, Department of Budget and Management - DBM), and Hon. Rosalia V. De Leon (National Treasurer).
Petition assails the implementation of the Motor Vehicle License Plate Standardization Program (MVPSP) of the Land Transportation Office (LTO), specifically the use of funds appropriated under Republic Act No. 10633 or the General Appropriations Act (GAA) of 2014.

The case is closely connected to the earlier case Jacomille v. Abaya (G.R. No. 212381), which questioned the procurement process for the MVPSP under the 2013 GAA for insufficiency of appropriations and failure to secure Multi-Year Obligational Authority (MYOA).
The Supreme Court dismissed Jacomille’s petition in 2015, finding the issue moot and academic due to sufficient appropriation under the 2014 GAA, but noted irregularities in the earlier procurement process in 2013.
Motion for reconsideration by Jacomille was denied in 2016, reinforcing that the 2014 GAA appropriated P4,843,753,000.00 for MVPSP, curing defects in the procurement and funding.

The DOTC, as the primary transportation policy agency, has the LTO as its line agency to register motor vehicles and issue license plates.
Due to proliferation of old, dilapidated, and counterfeited license plates affecting law enforcement and national security, the LTO formulated the MVPSP to standardize plates for both new and old vehicle registrants.
February 2013: Invitation to Bid was published with an Approved Budget for the Contract (ABC) worth approximately P3.85 billion under the 2013 GAA.
The bidding process involved pre-bid conferences and opening of bids, eventually awarding the contract to a joint venture between J. Knieriem B.V. Goes and Power Plates Development Concepts, Inc. (JKG-Power Plates).
Contract signing was delayed and only occurred on February 21, 2014, after the 2014 GAA had already appropriated funds for the program.
COA issued various Audit Observation Memoranda and eventually a Notice of Disallowance disapproving an advance payment of P477,901,329.00 to JKG-Power Plates due to alleged irregularities and violations of provisions in the Administrative Code, Government Auditing Code, DBM circulars, and Government Procurement Reform Act.
Petitioners filed the current special civil action challenging constitutionality of implementing the MVPSP using funds appropriated under the 2014 GAA, claiming:

Unconstitutional transfer of appropriations since MVPSP was not an item under the Motor Vehicle Registration and Driver's Licensing Regulatory Services in the 2014 GAA.
That this transfer deprived the President of item veto power.
Expenses of over P3 billion without appropriation under 2013 and 2014 GAAs were unconstitutional.

A temporary restraining order (TRO) was issued on June 14, 2016, enjoining the release and distribution of license plates.

The Office of the Solicitor General (OSG) admitted the 2014 GAA did not explicitly contain an appropriation for the MVPSP but claimed the transfer of funds was unconstitutional due to lack of authorization and lack of savings in the fund source.
JKG-Power Plates argued that the legality of the MVPSP was settled by the Court’s prior decisions and that COA's Notice of Disallowance was still pending review and not yet for judicial reconsideration.
Respondent former DOTC Secretary Abaya argued that:

The Jacomille decision was binding (stare decisis).
The 2014 GAA included appropriation for MVPSP under Motor Vehicle Registration and Driver’s Licensing Regulatory Services (MFO2).
There was no unconstitutional transfer of funds.

The 2014 GAA appropriated a total of P4,843,753,000.00 for the MFO2: Motor Vehicle Registration and Driver’s Licensing Regulatory Services.
The National Expenditure Program (NEP) for 2014 initially proposed P2,354,653,000.00 for MFO2, insufficient to cover MVPSP implementation.
DOTC requested a realignment to increase MFO2 budget by P2,489,600,100.00 to cover MVPSP.
Legislative hearings confirmed the increased budget was approved specifically for MVPSP under MFO2.
The Court held that the figure in the main text of the GAA (P4.843 billion) controlled over attached details and that the appropriation logically and specifically included plate-making as integral to vehicle registration.
The petitioners argued the appropriation was lump-sum, precluding item veto by the President, which was rejected by the Court citing performance-informed budgeting and the existence of line-items and specific purposes set out in the budget’s "Details of the FY 2014 Budget."

Whether the General Appropriations Act of 2014 included an appropriation for the implementation of the Motor Vehicle License Plate Standardization Program (MVPSP).

Whether the use of the appropriation under the 2014 GAA for the implementation of the MVPSP was constitutional, particularly with respect to alleged unconstitutional transfer of funds and violation of the President’s veto powers.