Case Summary (G.R. No. 235310)
The Case Background
Petitioner Aniceto D. Bertiz III challenges the legality of the LTO's application of remaining funds from the 2016 General Appropriations Act (GAA) toward the 2017 Driver's License Card Project. He seeks a prohibition against the public respondents from implementing the said project and claims the expenditures were unconstitutional due to lack of proper legislative appropriation for the identified fiscal year. The disbursements are anchored on Section 29(1), Article VI of the 1987 Philippine Constitution, which stipulates that no funds may be disbursed from the Treasury except pursuant to a law.
Legislative Framework
The 2016 GAA allocated PHP 587,497,000 for the issuance of driver's licenses. One contract was awarded for the procurement of driver’s license cards for PHP 187,080,000, leading to a resulting unspent balance of PHP 341,713,000. Meanwhile, in 2017, President Rodrigo Duterte signed the 2017 GAA with PHP 573,450,000 appropriated for the same purpose. The LTO intended to utilize the previous year's unused balance in conjunction with the new appropriations for a total Approved Budget for the Contract of PHP 836,000,000.
Legal Arguments Presented
Bertiz argues that the bidding process for the project was flawed and claims that the LTO's invitation for bids indicated a lack of proper funding source, leading to an unconstitutional expenditure of public funds. He alleges that the balance from the 2016 GAA never provided a specific legal basis for funding obligations in 2017, rendering the actions of public respondents unlawful.
Respondents' Defense
Dermalog and the public respondents counter that the appropriation for the 2016 GAA allowed for continuing appropriations into 2017. They assert that the LTO, by using the balance from the 2016 GAA in conjunction with the 2017 appropriations, stayed within the parameters set by law. They contend that the burden of establishing whether grave abuse of discretion occurred lies with the petitioner.
Court Rulings on Appropriation and Disbursement
The Court elucidated that "appropriation made by law" implies the necessity for a determined amount and a specified public purpose. It found that the continuing appropriation clause in the 2016 GAA permitted the LTO to utilize unspent funds for the same project in the next fiscal year without violating constitutional mandates. Additionally, the Court determined that committing overhead expenses for the driver's licenses was not unlawful, as sufficient funds existed across the appropriated amounts.
Conclusion on the Petition
The petition was ultimately dismissed for failure to prove severe abuse of discretion on the part of the respondents. The court clarified that it would not delve into the conduct of the bidding process, as this involve
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Case Overview
- The case involves a petition for certiorari and prohibition filed by Aniceto D. Bertiz III against various government officials and a joint venture, contesting the constitutionality of the Land Transportation Office's (LTO) actions regarding the funding and execution of the 2017 Driver's License Card Project (DLC Project).
- The petition is grounded on the assertion that public funds were disbursed without a lawful appropriation as mandated by Section 29(1), Article VI of the 1987 Constitution.
Background Information
- On December 22, 2015, Republic Act No. 10717, or the 2016 General Appropriations Act (GAA), was enacted, allocating P587,497,000.00 for the issuance of driver's licenses.
- The LTO initiated a bidding process for the 2016 DLC Project but faced delays due to legal issues.
- The LTO subsequently opted for direct contracting with AllCard Plastics Philippines, resulting in unspent funds amounting to P341,713,000.00 from the 2016 budget.
- In August 2016, the DOTr submitted a budget proposal for the 2017 DLC Project amounting to P528,793,000.00.
- On December 22, 2016, Republic Act No. 10924, or the 2017 GAA, was enacted, appropriating P573,450,000.00 for the same purpose.
Arguments Presented by the Petitioner
- The petitioner contends that the L