Case Digest (G.R. No. 236118) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In consolidated petitions G.R. Nos. 236118 and 236295, filed on December 13, 2017 and January 15, 2018 respectively, Act Teachers Rep. Antonio Tinio, Bayan Muna Rep. Carlos Isagani Zarate, and Anakpawis Rep. Ariel “Ka Ayik” Casilao challenged Republic Act No. 10963 (the “TRAIN Act”) before the Supreme Court via Rule 65 petitions for certiorari and prohibition, alleging that the Bicameral Conference Committee Report was ratified by the House of Representatives without a quorum on December 13, 2017, in violation of the 1987 Constitution and the House’s Internal Rules. They sought a temporary restraining order to enjoin implementation of the law. In G.R. No. 236295, Laban Konsyumer, Inc. and Atty. Victorio Mario A. Dimagiba, invoking taxpayer and consumer standing, assailed the TRAIN Act’s pass-on excise taxes on diesel, coal, LPG, and kerosene as regressive and confiscatory, violating due process and equal protection. The Office of the Solicitor General, representing respondents i Case Digest (G.R. No. 236118) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Petitions
- G.R. No. 236118 (“Tinio, et al.”)
- Petitioners: Representatives Tinio, Zarate, and Casilao.
- Relief sought: Certiorari and prohibition to annul RA 10963 (“TRAIN Act”) for lack of quorum and internal-rules violations in the House.
- G.R. No. 236295 (“Laban Konsyumer and Dimagiba”)
- Petitioners: Laban Konsyumer, Inc. and Atty. Dimagiba.
- Relief sought: Certiorari to strike excise taxes on diesel, coal, LPG, and kerosene as unconstitutional (regressive, confiscatory, discriminatory).
- Background of TRAIN Act
- RA 10963 (“Tax Reform for Acceleration and Inclusion Act”) amended the National Internal Revenue Code to fund “Build, Build, Build.”
- Initial bills (HB 5636, SB 1592) certified urgent; bicameral conference report ratified 13 Dec 2017.
- TRAIN Act enacted 19 Dec 2017; implemented reforms, including new/existing excise taxes and higher income-tax exemption thresholds.
- Procedural History
- Two petitions consolidated by Supreme Court resolution, 23 Jan 2018.
- Respondents’ consolidated comment: challenge dismissed for procedural defects and lack of merit.
- Petitioner replies and motions for injunctive relief (TRO, status quo ante, preliminary injunction).
- Court identification of eight issues for resolution, including jurisdiction, hierarchy, quorum, substantive constitutionality.
Issues:
- May the Supreme Court take cognizance under its judicial power and certiorari jurisdiction?
- Did petitioners violate the doctrine of hierarchy of courts?
- Must Congress (both Houses) be impleaded as indispensable parties?
- Does presidential immunity from suit bar Tinio, et al.’s challenge to President Duterte?
- Was the TRAIN Act validly enacted into law?
- Is Section 48 (coal excise tax) of TRAIN a prohibited rider under Art. VI, Sec. 24 of the Constitution?
- Do the excise‐tax provisions violate due process (confiscatory, arbitrary exaction)?
- Do the excise‐tax provisions violate equal protection and Art. VI, Sec. 28(1) (progressivity requirement)?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)