Pimentel III vs. House of Representatives~Colmenares vs. Executive Secretary Lucas Bersamin~1Sambayan Coalition vs. House of Representatives

Facts:

Aquilino Pimentel III v. House of Representatives (consolidated with Bayan Muna v. Executive Secretary and 1Sambayan Coalition v. House of Representatives), G.R. Nos. 274778, 275405 & 276233, December 03, 2025, the Supreme Court En Banc, Lazaro-Javier, J., writing for the Court.

Petitioners (senators, civic organizations, labor groups, and citizens-taxpayers) challenged Special Provision 1(d) of Republic Act No. 11975 (the 2024 General Appropriations Act or 2024 GAA) and DOF Circular No. 003-2024, which directed GOCCs, including Philippine Health Insurance Corporation (PhilHealth), to remit a computed “fund balance” to the National Treasury. The contested transfer was said to include PHP 89.9 billion identified from PhilHealth's accounts; PhilHealth remitted PHP 20.0 billion (May 10, 2024), PHP 10.0 billion (Aug. 21, 2024) and PHP 30.0 billion (Oct. 16, 2024), with a remaining PHP 29.9 billion stayed by a TRO.

The petitions trace the fiscal context: the Sin Tax laws (RA 10351, RA 11346, RA 11467) earmarked portions of excise taxes for implementation of the Universal Health Care Act (UHCA) (RA 11223), and Section 11 of the UHCA prescribes PhilHealth’s actuarially-determined reserve fund rules. Congress enacted the 2024 GAA after bicameral conferences that increased unprogrammed appropriations and inserted Special Provision 1(d), and the DOF then issued implementing guidelines. Petitioners sought certiorari/prohibition and injunctive relief; the Court consolidated the petitions, issued a TRO (Oct. 29, 2024) to stop further remittances, held extensive oral arguments with amici curiae, and received memoranda. The Office of the Solicitor General (OSG) defended the measures as a lawful budgetary management step; amici offered economic, actuarial, and policy perspectives....(Pro-only)

Issues:

• Do petitioners satisfy the procedural requisites for the Court to exercise its expanded power of judicial review (standing, ripeness, earliest opportunity, and lis mota)?
• Was the President’s September 20, 2023 certification of urgency for House Bill No. 8980 tainted with grave abuse of discretion?
• Are Special Provision 1(d) of the 2024 GAA and DOF Circular No. 003-2024 unconstitutional when (a) tested as a rider (germaneness / appropriateness) and (b) as instruments that (i) divert PhilHealth funds in violation of Section 11 of the UHCA and the Sin Tax laws and (ii) implicate the constitutional ban on transferring special funds (Art. VI, Sec. 29(3))?
• Did DOF Circular No. 003-2024 violate Section 70 of the 2023 GAA (cash-budgeting rules) by ordering remittance before year-end?
• May the Court, in this certiorari/prohibition remedy, adjudge criminal liability (technical malversation / plunder) against the DOF Secretary or others for the remittance?
• May petitioners obtain judicial guidance or parameters on the President’s power to certify a bill as urgent?
• If Special Provision 1(d) and DOF Circular No. 003...(Pro-only)

Ruling:

• (Pro-only)

Ratio:

• (Pro-only)

Doctrine:

• (Pro-only)