Case Digest (G.R. No. 94571)
Facts:
Teofisto T. Guingona, Jr. and Aquilino Q. Pimentel, Jr. v. Hon. Guillermo Carague, Hon. Rozalina S. Cajucom and Commission on Audit, G.R. No. 94571, April 22, 1991, Supreme Court En Banc, Gancayco, J., writing for the Court.Petitioners, both Senators, filed a petition in the Supreme Court challenging the constitutionality of the automatic appropriation for debt service reflected in the proposed 1990 national budget. The 1990 budget, as presented in the President’s Budget of Expenditures and Sources of Financing, totaled P233.5 billion: about P98.4 billion characterized as automatic appropriations (of which P86.8 billion was for debt service) plus P155.3 billion to be provided under Republic Act No. 6831 (the General Appropriations Act). Petitioners contrasted the P86.8 billion for debt service with the appropriation for the Department of Education, Culture and Sports (roughly P27 billion) and alleged that the automatic debt-service appropriation violated constitutional mandates favoring education.
The automatic appropriations rested on a statutory and regulatory framework composed of R.A. No. 4860 (as amended), P.D. No. 81 (amending R.A. No. 4860), P.D. No. 1177 (Section 31 on automatic appropriations), and P.D. No. 1967 (appropriating such amounts as may be necessary to effect payments on loans). Petitioners sought declarations that P.D. No. 81, Section 31 of P.D. No. 1177, and P.D. No. 1967 were unconstitutional and injunctive relief to restrain disbursements pursuant to the automatic appropriations.
Respondents argued the petition raised political questions and that the decrees remained operative under the Constitution. The Court first addressed justiciability, relying on its prior ruling in Gonzales v. Macaraig, Jr. (G.R. No. 87656) to hold there was an actual justiciable controversy. The Court then considered (1) whether the debt-service appropriation violated Section 5(5), Article XIV (education priority); (2) whether the presidential decrees and statutes authorizing automatic appropriations remained operative under the 1987 Constitution (citing the transitory Clause, Section 3, Article XVIII); and (3) whether those measures violated Section 29(1), Article VI (no money paid except pursuant to an appropriation made by law) or constituted an unconstitutional delegation of legislative power. The Supreme Court resolved these questions in a decision dis...(Subscriber-Only)
Issues:
- Is the appropriation of P86.8 billion for debt service in the 1990 budget violative of Section 5(5), Article XIV of the 1987 Constitution (the requirement that the State assign the highest budgetary priority to education)?
- Are P.D. No. 81, Section 31 of P.D. No. 1177, and P.D. No. 1967 still operative under the 1987 Constitution (Section 3, Article XVIII) so as to authorize automatic appropriations for debt service?
- Do those presidential decrees and related laws violate Section 29(1), Article VI of the 1987 Constitution or amount to an undue delegation of legislative power by allowing payments "as and when they shall become du...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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