Title
IN RE: Supreme Court Judicial Independence vs. Judiciary Development Fund
Case
UDK-15143
Decision Date
Jan 21, 2015
Petitioner sought mandamus to protect judicial independence against proposed bills altering judiciary funds; SC denied, citing lack of actual case, standing, and ministerial duty.

Case Digest (G.R. No. 205741)
Expanded Legal Reasoning Model

Facts:

  • Nature of the Petition
  • Petitioner Rolly Mijares, a Filipino citizen and taxpayer, filed a letter‐petition dated August 27, 2014, docketed as UDK-15143, praying for a writ of mandamus to compel the Supreme Court to assert its judicial independence and fiscal autonomy.
  • He challenges proposed congressional bills aiming to abolish the Judiciary Development Fund (JDF) established under Presidential Decree No. 1949 and replace it with a Judiciary Support Fund (JSF) whose collections would be remitted to the National Treasury for appropriation by Congress.
  • Legislative and Executive Developments
  • House Bill No. 4690 (filed July 2014) would require the Supreme Court to remit its JDF collections to the National Treasury.
  • House Bill No. 4738 (filed July 2014) proposes creation of the JSF under the National Treasury, repealing PD 1949.
  • On July 14, 2014, President Aquino publicly criticized the Supreme Court’s decisions in the PDAF and DAP cases and urged the Court to review its rulings.
  • Procedural History
  • The letter‐petition was referred to the Supreme Court en banc and formally docketed UDK-15143.
  • The Clerk of Court en banc processed the petition, and all Justices were notified.
  • The Court resolved to deny the petition for failure to meet the requisites of judicial review and mandamus.

Issues:

  • Justiciability and Standing
  • Whether there exists an actual case or controversy ripe for judicial review of proposed bills.
  • Whether petitioner has personal and substantial interest or direct injury sufficient to confer standing.
  • Mandamus Requirements
  • Whether the petition satisfies Rule 65, Sec. 3, 1997 Rules of Civil Procedure, for issuance of a writ of mandamus.
  • Whether there is a clear ministerial duty on the part of the Court and lack of any other plain, speedy, and adequate remedy.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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