Title
Mandanas vs. Ochoa
Case
G.R. No. 199802
Decision Date
Apr 10, 2019
The Supreme Court declares certain provisions of the Local Government Code unconstitutional, ruling that Congress exceeded its authority by limiting the base amount for determining the just share of local government units to national internal revenue taxes, and orders the inclusion of all collections of national taxes in the computation of the LGUs' just share.
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Case Digest (G.R. No. 199802)

Facts:

  • The case involves two consolidated petitions filed by local government officials and a congressman.
  • Petitioners include Congressman Hermilando I. Mandanas, Mayor Efren B. Diona, Mayor Antonino Aurelio, Kagawad Mario Ilagan, Barangay Chair Perlito Manalo, Barangay Chair Medel Medrano, Barangay Kagawad Cris Ramos, Barangay Kagawad Elisa D. Balbago, and Atty. Jose Malvar Villegas.
  • Respondents are Executive Secretary Paquito Ochoa, Secretary Cesar Purisima of the Department of Finance, Secretary Florencio H. Abad of the Department of Budget and Management, Commissioner Kim Jacinto-Henares of the Bureau of Internal Revenue, and National Treasurer Roberto Tan of the Bureau of the Treasury.
  • The petitions challenge the constitutionality of provisions in the Local Government Code (Republic Act No. 7160) that limit the base amount for determining LGUs' share to national internal revenue taxes.
  • The Supreme Court found the phrase "internal revenue" in Section 284 of the Local Government Code unconstitutional and ordered its deletion.
  • The Court directed the inclusion of all national tax collections in the computation of LGUs' share, except for special purpose funds and allotments for the utilization and development of national wealth.
  • The initial decision was made on July 3, 2018, and the OSG's motion for reconsideration was denied on April 10, 2019.

Issue:

  • (Unlock)

Ruling:

  1. Yes, Congress exceeded its authority by limiting the base amount for LGUs to national internal revenue taxes.
  2. Yes, the phrase "internal revenue" in Sections 284, 285, 287, and 290 of the Local Government Code is unconstitutional and should be deleted.
  3. Yes, taxes including tariff and customs duties, value-added taxes collected in the ARMM, and oth...(Unlock)

Ratio:

  • The decision was based on Section 6, Article X of the 1987 Philippine Constitution, mandating LGUs to have a just share in national taxes.
  • The term "national taxes" in the Constitution is broader than &quo...continue reading

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