Case Digest (G.R. No. 71977)
Facts:
In Demetrio G. Demetria et al. v. Hon. Manuel Alba and Victor Macalingcag, petitioners—members of the Batasang Pambansa and concerned taxpayers—filed on September 19, 1985 an original petition for prohibition with prayer for preliminary injunction directly before the Supreme Court en banc. They assailed the constitutionality of the first paragraph of Section 44 of Presidential Decree No. 1177 (the “Budget Reform Decree of 1977”), alleging it unlawfully empowers the President to transfer appropriations without legislative specification, undermining safeguards against misapplication of public funds and unduly delegating legislative power. Named as respondents were Hon. Manuel Alba, Minister of the Budget, and Victor Macalingcag, Treasurer of the Philippines. The Solicitor General, in his Comment, challenged petitioners’ standing, contended that the petition presented no justiciable controversy—especially after the abolition of the Batasang Pambansa under the Freedom Constitution—aCase Digest (G.R. No. 71977)
Facts:
- Parties and Relief Sought
- Petitioners: Members of the Batasang Pambansa, concerned citizens, and taxpayers.
- Relief: Prohibition with prayer for preliminary injunction to test constitutionality of first paragraph, Section 44, Presidential Decree No. 1177 (“Budget Reform Decree of 1977”).
- Grounds of Challenge
- Infringement of the fundamental law by authorizing illegal transfer of public moneys.
- Failure to specify objectives and purposes for transfers.
- Override of constitutional safeguards in approving appropriations.
- Undue delegation of legislative power to the Executive.
- Actions taken without or in excess of authority by the Budget Minister and the Treasurer.
- Procedural History and Contentions
- Solicitor General’s Comment: Questions standing, justiciability, asserts enactment under 1973 Constitution Article VIII(16)(5), and that prohibition will not lie between coordinate branches.
- Petitioners’ Reply: Suggest holding proceedings in abeyance pending political developments.
- Public Respondents’ Rejoinder and Motion to Dismiss: Argue mootness by Freedom Constitution, invoke Ashwander principles against advisory opinions.
- Supreme Court Action: Denied motion to dismiss, found issues of continuing public importance, and upheld petitioners’ standing as taxpayers.
Issues:
- Standing and Justiciability
- Whether petitioners, as taxpayers and Assembly members, have legal standing to challenge Section 44(1).
- Whether the petition is moot and academic following constitutional changes.
- Availability of Prohibition
- Whether a writ of prohibition lies to enjoin executive acts under Section 44(1).
- Whether coordinate-branch immunity bars judicial control of Executive budget actions.
- Constitutionality of Section 44(1), P.D. No. 1177
- Whether it conflicts with Section 16(5), Article VIII of the 1973 Constitution.
- Whether it constitutes an undue delegation of legislative power.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)