Case Digest (G.R. No. 99886) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Osmena v. Orbos, G.R. No. 99886, decided En Banc on March 31, 1993 under the 1987 Constitution, petitioner John H. Osmena sought Rule 65 remedies against Executive Secretary Oscar Orbos, Secretary of Finance Jesus Estanislao, Head of the Office of Energy Affairs Wenceslao de la Paz, Chairman Rex V. Tantiongco, and the Energy Regulatory Board (ERB). Osmena challenged the creation of the Oil Price Stabilization Fund (OPSF) as a “trust account” pursuant to P.D. No. 1956 (1984) and its amendment by E.O. 137 (1987), alleging violation of Article VI, Section 29(3) on special funds. He also assailed Section 8(1)(c) of P.D. 1956 as an undue delegation of legislative power to the ERB (alleged breach of Article VI, Section 28(2)), the propriety of reimbursements by the OPSF to oil companies, and the validity of the ERB’s December 10, 1990 order increasing pump prices. The petition urged nullification of the trust account, prohibition of unauthorized claims, and rollback of petroleum pr Case Digest (G.R. No. 99886) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and relief sought
- Petitioner: John H. Osmeña.
- Respondents: Executive Secretary Orbos; Secretary of Finance Estanislao; Head of Office of Energy Affairs Dela Paz; ERB Chairman Tantiongco; Energy Regulatory Board.
- Requested remedies: writs of certiorari, prohibition and mandamus under Rule 65 to nullify ERB Order of December 10, 1990 and rollback pump prices.
- Creation and amendments of the Oil Price Stabilization Fund (OPSF)
- P.D. No. 1956 (October 10, 1984): established a Special Account in the General Fund to reimburse oil companies for cost increases due to exchange rate adjustments and world oil price hikes.
- E.O. No. 1024 (May 9, 1985): reclassified OPSF as a “trust liability account” and authorized investment in government securities, with earnings accruing to the fund.
- E.O. No. 137 (February 27, 1987): amended P.D. 1956 to expand reimbursement grounds for underrecoveries arising from reductions in domestic petroleum prices, with amounts to be determined by the Minister of Finance in consultation with the ERB.
- Financial state and administrative action
- As of March 31, 1991, OPSF showed a P 12.877 billion deficit.
- To arrest the deficit, ERB issued an order on December 10, 1990 approving pump price increases, projected to eliminate the deficit within six months.
- Respondents continued to accept and process claims allegedly unauthorized under P.D. 1956, worsening the deficit.
- Constitutional and statutory challenges
- Article VI, Section 29(3) of the Constitution: petitioner argued OPSF monies are a “special fund” and cannot be treated as a trust account.
- Article VI, Section 28(2): petitioner claimed P.D. 1956 8(1)(c) – delegation to ERB to impose additional imposts – is an undue delegation of “taxing power” lacking quantitative limits.
- Reimbursement claims: petitioner challenged financing charges, inventory losses, fuel oil sales to NPC and overpayment refunds as beyond authorized scope of P.D. 1956.
Issues:
- Whether the Oil Price Stabilization Fund, as reclassified into a trust account, violates Article VI, Section 29(3) of the Constitution governing special funds.
- Whether Section 8(1)(c) of P.D. 1956, delegating authority to ERB to impose additional amounts on petroleum products, constitutes an unauthorized delegation of legislative (taxing) power under Article VI, Section 28(2).
- Whether reimbursements paid out of the OPSF—specifically financing charges, inventory losses, fuel oil sales to NPC and overpayment refunds—are lawful under P.D. 1956 as amended.
- Whether the ERB Order of December 10, 1990 is null and whether pump prices must be rolled back to pre-order levels.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)