Case Digest (G.R. No. 199802) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the consolidated petitions of Mandanas, et al. v. Ochoa, Jr. (G.R. No. 199802) and Garcia v. Ochoa, Jr. (G.R. No. 208488), decided July 3, 2018 by the Supreme Court En Banc, local legislators and barangay officials headed by Congressman Hermilando I. Mandanas and Congressman Enrique T. Garcia, Jr. challenged the computation and release of the Internal Revenue Allotment (IRA) of Local Government Units (LGUs). They alleged that Section 284 of Republic Act No. 7160 (the Local Government Code of 1991) unlawfully restricted the IRA base to national internal revenue taxes and excluded collections of Value-Added Tax, Excise Tax, and Documentary Stamp Tax by the Bureau of Customs, as well as various proceeds under special laws. Mandanas sought inclusion of ₱60.75 billion for FY 2012 and arrears of ₱438 billion for FY 1992–2011; Garcia sought to strike the phrase “internal revenue” from Section 284 and compel computation on all national taxes. Common respondents were Executive Secreta Case Digest (G.R. No. 199802) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Constitutional and Legal Framework
- 1987 Constitution, Article X mandates local autonomy and fiscal decentralization:
- Section 5 – LGUs may create own revenue sources subject to congressional guidelines.
- Section 6 – LGUs shall have a just share in the national taxes, as determined by law, automatically released to them.
- Section 7 – LGUs entitled to an equitable share in proceeds from development of national wealth in their areas.
- Republic Act No. 7160 (Local Government Code of 1991) implements these mandates:
- Section 3(d) – Operative principles of decentralization.
- Section 284 – IRA (Internal Revenue Allotment) fixed at 30%, 35%, then 40% of *national internal revenue taxes* (NIRTs).
- Sections 285–286 – Allocation among provinces, cities, municipalities, barangays; quarterly release.
- Implementing rules and related laws, including Development Budget Coordination Committee (DBCC) Resolution No. 2003-02, limited the base for IRA to cash collections certified by the Bureau of Internal Revenue (BIR).
- G.R. No. 199802 (Mandanas et al.)
- Petitioners (LGU officials of Batangas) challenge the computation of their IRA for FY 2012 under the 2012 General Appropriations Act (GAA).
- They allege that certain NIRTs collected by the Bureau of Customs (BOC)—value-added taxes (VAT), excise taxes, documentary stamp taxes (DST)—were excluded from the base, depriving LGUs of P60.75 billion in FY 2012 and P438.1 billion for 1992–2011.
- They seek certiorari, prohibition, and mandamus to compel respondents to include all BOC-collected NIRTs in the FY 2012 IRA and to pay arrears.
- G.R. No. 208488 (Garcia)
- Petitioner Congressman Enrique T. Garcia Jr. (later substituted) challenges Section 284 of the LGC as unconstitutional, arguing “national internal revenue taxes” narrows the Constitution’s “national taxes.”
- He contends Congress exceeded its power by excluding certain national taxes (customs duties, special-purpose taxes) and by requiring annual appropriation for release.
- He prays for mandamus to compel computation of LGU shares based on all national taxes, without deductions, and for payment of shortfalls.
Issues:
- Is mandamus a proper remedy to redress the alleged budgetary exclusions and compel payments?
- Does Section 284 of the LGC unconstitutionally narrow “national taxes” to “national internal revenue taxes”?
- Are the existing IRA shares under the GAA consistent with the constitutional mandate for LGUs to have a just share in national taxes?
- Are petitioners entitled to the reliefs prayed, including arrears from prior years?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)