G.R. No. 195619 - Planters Development Bank vs. Chandumal

On February 2, 1989, the Senate adopted Resolution No. 381 authorizing its Committee on Finance to file suit in the Supreme Court contesting the constitutionality of the President’s line-item veto of certain provisions in the General Appropriations Bill for FY 1989 (H.B. No. 19186).
Petitioners are members and ex-officio members of that Committee—and substantial taxpayers—whose interests were purportedly affected by the veto.

On December 16, 1988, Congress passed H.B. No. 19186 (the FY 1989 General Appropriations Bill). On December 29, 1988, the President signed it into law as R.A. No. 6688 but vetoed seven “Special Provisions” and Section 55 of the General Provisions (the “anti-augmentation provision”).
On August 8, 1989, Congress passed H.B. No. 26934 (the FY 1990 General Appropriations Bill), later enacted as R.A. No. 6831. The President vetoed Section 16, which combined the “Use of Savings” authorization with the same anti-augmentation restriction.

On April 11, 1989, petitioners filed a petition for prohibition and mandamus (with a prayer for preliminary injunction) challenging the constitutionality of the vetoed provisions and seeking to enjoin implementation of R.A. No. 6688.
After answers, comments, and consolidated memoranda—including supplemental petitions on the FY 1990 veto—oral arguments were heard on September 11, 1990, and the case was submitted for decision.

Whether the dispute between the Senate and the Executive over the line-item veto power presented a justiciable controversy.
Whether, under Article VI, Section 27(2) of the 1987 Constitution, the President’s power to veto “any particular item or items in an appropriation . . . bill” extends to provisions such as Section 55 (FY 1989) and Section 16 (FY 1990).
Whether the vetoed sections—by prohibiting the augmentation of disapproved or reduced appropriations—unconstitutionally nullified the augmentation power granted by Article VI, Section 25(5) of the Constitution and by existing statutes (Presidential Decree No. 1177, Secs. 44–45; GAA 1989 Sec. 12).