Case Digest (G.R. No. 113105)
Facts:
In G.R. Nos. 113105, 113174, 113766, and 113888, decided en banc on August 19, 1994, various taxpayers, the Philippine Constitution Association, individual petitioners, and Senators (including Angara, Gonzales, Roco, Tanada, and Romulo) challenged provisions and vetoes in Republic Act No. 7663 (General Appropriations Act of 1994). House Bill No. 10900 was approved by both Houses of Congress on December 17, 1993, and signed by President Ramos on December 30, 1993, becoming law, but accompanied by a Presidential Veto Message striking and conditioning numerous special provisions. Petitioners sought writs of certiorari, prohibition, mandamus, and prohibition against respondents—including the Secretary of Budget and Management, the National Treasurer, the Commission on Audit, and the Executive Secretary—alleging that Congress and the President had exceeded or abused their constitutional prerogatives regarding the Countrywide Development Fund, realignment of allocations, debt service,Case Digest (G.R. No. 113105)
Facts:
- Cases and Parties
- Four consolidated petitions (G.R. Nos. 113105, 113174, 113766, 113888) filed by:
- Taxpayer associations and individual taxpayers
- Senators suing in personal and representative capacity
- Respondents include the Executive Secretary, Secretary of Budget and Management, National Treasurer, Commission on Audit
- 1994 General Appropriations Act (GAA of 1994)
- House Bill No. 10900 passed December 17, 1993; enacted as Republic Act No. 7663 on December 30, 1993
- President signed the law but issued a Veto Message striking or conditioning various special provisions
- No congressional override of vetoes
- Challenged Provisions and Vetoes
- Countrywide Development Fund (“pork barrel”) authorizes members of Congress to propose projects
- Realignment clause allowing individual legislators to transfer their operational expense allocations
- Debt service provisions giving payment highest priority and ceiling clause subject to presidential/congressional approval
- Numerous special provisions and vetoes in items for:
- State Universities and Colleges (revolving funds, income use)
- Department of Public Works and Highways (30% contract/70% force-account ratio; overhead deductions)
- Armed Forces of the Philippines (medicine purchase formulary; modernization fund conditions; pension‐fund savings)
- Citizen Armed Forces Geographical Units (CAFGU deactivation and separation benefits)
- Judiciary, Commission on Audit (COA), Ombudsman, Commission on Human Rights (CHR) – augmentation from savings; guidelines
- Locus Standi
- Established that taxpayers and individual Senators have personal and substantial interest to challenge executive encroachment on legislative powers
- Congressional institution and its members may protect prerogatives through judicial review when veto is claimed ultra vires
Issues:
- Legislative vs. Executive Powers
- Whether the Countrywide Development Fund improperly delegates executive implementation duties to individual legislators
- Whether members of Congress can realign appropriated funds for their operational expenses
- Budgetary Priorities
- Whether Congress violated the constitutional mandate to assign highest budgetary priority to education by appropriating more for debt service
- Validity of debt‐ceiling provision and presidential veto thereof
- Scope of Presidential Veto
- Whether the President may item‐veto special provisions (“provisions”) in an appropriations act without vetoing entire items
- Whether “inappropriate provisions” (provisions relating to funds or matters beyond the item) are subject to item veto
- Specific Vetoed Provisions
- SUC revolving funds and income-use provisions
- DPWH maintenance ratio (30% contract; 70% force account)
- AFP medicine formulary compliance
- AFP modernization fund – requirement of congressional approval; prohibition on specified acquisitions
- AFP pension‐fund augmentation from savings
- CAFGU deactivation and separation benefits tied to presidential approval
- Conditions on Judiciary, COA, Ombudsman, CHR – augmentation from savings; executive‐issued guidelines
- DPWH and National Housing Authority (NHA) releases subject to presidential guidelines/approval
- Impoundment and Faithful Execution
- Whether the President may defer or impound appropriated funds when implementation conflicts with executive policy
- Extent of the President’s power to issue administrative guidelines in executing appropriations
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)