MODULE 7: LEGISLATIVE DEPARTMENT (cont.

1. Santiago v. Guingona, Jr.

Facts:
The case "Defensor-Santiago v. Guingona, Jr." (G.R. No. 134577) was decided by the Supreme Court of
the Philippines on November 18, 1998, with Justice Panganiban as the ponente. Petitioners, Senators
Miriam Defensor Santiago and Francisco S. Tatad, filed a petition for quo warranto under Rule 66, Section
5 of the Rules of Court, seeking to oust Senator Teofisto T. Guingona Jr. as the minority leader of the
Senate and to declare Senator Tatad as the rightful minority leader. The Senate convened on July 27,
1998, for the first regular session of the eleventh Congress, with Sen. John Henry R. Osmeña as the
presiding officer. The Senate's composition included members from various political parties and
independents. During the session, Sen. Marcelo B. Fernan was elected Senate President by a vote of 20
to 2. Sen. Tatad, who was also nominated for Senate President but lost, claimed the position of minority
leader, asserting that only those who voted for him constituted the minority. However, the seven
Lakas-NUCD-UMDP senators elected Sen. Guingona as the minority leader, and he was formally
recognized by the Senate President. The petitioners alleged that Sen. Guingona was unlawfully holding
the position of minority leader, which they claimed rightfully belonged to Sen. Tatad. The case was
submitted for decision without need for memoranda on September 29, 1998.

Issues
1. Does the Court have jurisdiction over the petition?
2. Was there an actual violation of the Constitution?
3. Was Respondent Guingona usurping, unlawfully holding, and exercising the position of Senate
minority leader?
4. Did Respondent Fernan act with grave abuse of discretion in recognizing Respondent Guingona
as the minority leader?

Ruling:
1. The Court ruled that it has jurisdiction over the petition.
2. The Court found no constitutional or legal infirmity or grave abuse of discretion in the recognition
of Respondent Guingona as the Senate minority leader.
3. The Court held that Respondent Guingona was not usurping, unlawfully holding, or exercising the
position of Senate minority leader.
4. The Court determined that Respondent Fernan did not act with grave abuse of discretion in
recognizing Respondent Guingona as the minority leader.

Ratio:
The Court's jurisdiction was affirmed based on the expanded judicial power under the 1987 Constitution,
which includes the duty to determine whether there has been a grave abuse of discretion by any branch
or instrumentality of the government. The Court emphasized that the issue of who constitutes the Senate
minority leader is an internal matter of the Senate, and no constitutional provision explicitly defines the
roles of majority and minority leaders. The Court found that the Senate's internal rules and practices did
not support the petitioners' claim that only those who voted for the losing nominee for Senate President
could be considered the minority. The Court also noted that the Senate has the autonomy to determine its
own rules and procedures, and there was no clear violation of the Constitution, laws, or Senate rules in
the recognition of Sen. Guingona as the minority leader. The Court concluded that there was no grave
abuse of discretion by Senate President Fernan in recognizing Sen. Guingona, as the decision was made
after due deliberation and consensus among the senators.

2. Bantay Republic Act or BA-RA 7941 v. COMELEC

Facts:
The case of Bantay Republic Act or BA-RA 7941 v. Commission on Elections (G.R. Nos. 177271 &
177314) was decided on May 4, 2007, by the Philippine Supreme Court. The petitioners, Bantay Republic
Act (BA-RA 7941) represented by Mr. Ameurfino E. Cinco, and Urban Poor for Legal Reforms (UP-LR)
represented by Mrs. Myrna P. Porcare, along with Rep. Loretta Ann P. Rosales, Kilosbayan Foundation,
and Bantay Katarungan Foundation, filed consolidated petitions for certiorari and mandamus against the
Commission on Elections (Comelec). The petitions sought to nullify certain Comelec resolutions
accrediting various party-list groups for the May 14, 2007, elections without determining the qualifications
of their nominees. The petitioners also requested the disclosure of the names of the nominees of these
party-list groups, which Comelec had refused to release, citing confidentiality. The lower court had not
resolved the urgent petition to disqualify the nominees of certain party-list organizations filed by BA-RA
7941 and UP-LR. The case was brought to the Supreme Court to address these issues.

Issue:
1. Did the Comelec violate the right to information and free access to documents as guaranteed by
the Constitution by refusing to reveal the names of the nominees of the various party-list groups?
2. Is the Comelec constitutionally mandated to disclose the names of the party-list nominees to the
public?

Ruling:
1. Yes, the Comelec violated the right to information and free access to documents as guaranteed
by the Constitution.
2. Yes, the Comelec is constitutionally mandated to disclose the names of the party-list nominees to
the public.

Ratio:
The Supreme Court ruled that the Comelec's refusal to disclose the names of the party-list nominees
violated the constitutional right to information and the policy of full public disclosure. The Court
emphasized that the right to information is a public right, and any citizen can challenge any attempt to
obstruct this right. The Court found that the Comelec's interpretation of Section 7 of R.A. 7941, which
prohibits the inclusion of nominees' names in the certified list posted in polling places, was overly broad
and not intended to be an absolute bar to public disclosure. The Court held that the Comelec's stance
impinged on the fundamental right to information and hindered the free and intelligent casting of votes.
The Court ordered the Comelec to immediately disclose and release the names of the nominees of the
party-list groups accredited to participate in the May 14, 2007, elections and to submit compliance within
five days.
 3. Ongsiako-Reyes v. COMELEC

Facts:
The case of "Reyes v. Commission on Elections" involves a petition filed by Regina Ongsiako Reyes
against the Commission on Elections (COMELEC) and Joseph Socorro B. Tan. The petition challenges
the cancellation of Reyes' Certificate of Candidacy (COC) for the position of Representative of the lone
district of Marinduque. The cancellation was based on allegations of material misrepresentations
regarding her citizenship, residency, and marital status. On October 31, 2012, Tan, a registered voter and
resident of Torrijos, Marinduque, filed an Amended Petition to Deny Due Course or to Cancel Reyes'
COC, citing several misrepresentations: (1) Reyes claimed to be single when she was married to
Congressman Herminaldo I. Mandanas of Batangas; (2) she claimed to be a resident of Brgy. Lupac,
Boac, Marinduque, while allegedly residing in Bauan, Batangas, and Quezon City; (3) discrepancies in
her date of birth; (4) she claimed not to be a permanent resident of another country while allegedly being
a permanent resident or immigrant of the United States; and (5) she claimed to be a Filipino citizen while
allegedly being an American citizen. Reyes countered these allegations, arguing that her marriage to
Congressman Mandanas was void ab initio, thus his residence could not be attributed to her. She also
provided a Certificate of Live Birth showing her birthdate as July 3, 1964, and denied the allegations of
her American citizenship. The COMELEC First Division, on March 27, 2013, canceled Reyes' COC,
finding that she failed to comply with the requirements of Republic Act No. 9225 (Citizenship Retention
and Re-acquisition Act of 2003) and did not meet the one-year residency requirement under the 1987
Constitution. Reyes' Motion for Reconsideration was denied by the COMELEC En Banc on May 14, 2013.
Despite her proclamation as the winner of the May 13, 2013 elections and taking her oath of office on
June 5, 2013, the COMELEC issued a Certificate of Finality on June 5, 2013, declaring its May 14, 2013
Resolution final and executory.

Issue:
1. Whether the COMELEC had jurisdiction over Reyes after her proclamation and oath of office.
2. Whether the COMELEC committed grave abuse of discretion by admitting "newly-discovered
evidence" without proper testimony and violating Reyes' right to due process.
3. Whether the COMELEC erred in declaring Reyes not a Filipino citizen and not meeting the
residency requirement.
4. Whether the COMELEC imposed additional qualifications for Members of the House of
Representatives beyond those enumerated in the 1987 Constitution.

Ruling:
1. The Supreme Court ruled that the COMELEC retained jurisdiction over Reyes' qualifications
despite her proclamation and oath of office.
2. The Court found no grave abuse of discretion by the COMELEC in admitting the
"newly-discovered evidence" and ruled that Reyes was given ample opportunity to present her
case.
3. The Court upheld the COMELEC's finding that Reyes was not a Filipino citizen and did not meet
the residency requirement.
4. The Court ruled that the COMELEC did not impose additional qualifications but merely applied
the constitutional requirements.

Ratio:
 1. The Court held that the jurisdiction of the House of Representatives Electoral Tribunal (HRET)
begins only after a candidate has assumed office. Since Reyes had not yet assumed office, the
COMELEC retained jurisdiction. The Court cited Section 17, Article VI of the 1987 Constitution
and previous rulings, emphasizing that a candidate is considered a Member of the House of
Representatives only after a valid proclamation, a proper oath, and assumption of office.
2. The Court noted that the COMELEC is not bound by strict rules of evidence and that the
proceedings in a petition to deny due course or to cancel a COC are summary in nature. The
"newly-discovered evidence" was properly admitted, and Reyes was given ample opportunity to
argue her case. The Court emphasized that procedural due process in administrative
proceedings requires only that the party be given an opportunity to be heard.
3. The Court found that Reyes failed to prove her Filipino citizenship and one-year residency in
Marinduque. The COMELEC's findings were based on substantial evidence, including records
from the Bureau of Immigration showing that Reyes was a holder of a U.S. passport. Reyes did
not provide sufficient evidence to counter these findings, and her Affidavit of Renunciation of
Foreign Citizenship was deemed insufficient.
4. The Court ruled that the COMELEC did not impose additional qualifications but merely applied
the constitutional requirements that a candidate must be a natural-born Filipino citizen and must
have one-year residency prior to the date of elections. The COMELEC's inquiry into Reyes'
compliance with Republic Act No. 9225 was necessary to determine her eligibility.

4. Daza v. Singson, 180 SCRA 496

Facts:
The case of Daza v. Singson (G.R. No. 86344) was decided by the Supreme Court of the Philippines on
December 21, 1989. The petitioner, Representative Raul A. Daza, contested his removal from the
Commission on Appointments and the subsequent appointment of Representative Luis C. Singson in his
place. Following the congressional elections on May 11, 1987, the House of Representatives allocated its
twelve seats in the Commission on Appointments among various political parties, including the Liberal
Party, to which Daza belonged. On September 16, 1988, a political realignment occurred when 24
members of the Liberal Party resigned and joined the newly-formed Laban ng Demokratikong Pilipino
(LDP), increasing its membership to 159 and reducing the Liberal Party to 17 members. As a result, the
House revised its representation in the Commission, removing Daza and appointing Singson from the
LDP. Daza filed a petition on January 13, 1989, challenging his removal and Singson's appointment,
arguing that his election to the Commission was permanent and that the LDP was not a duly registered
political party. The respondents contended that the issue was political and beyond the Court's jurisdiction,
and that the House had the authority to revise its representation based on proportional representation.

Issue:
1. Does the Supreme Court have jurisdiction to review the House of Representatives' decision to
change its representation in the Commission on Appointments?
2. Was the reorganization of the House representation in the Commission on Appointments valid,
given the political realignment and the status of the LDP as a political party?

Ruling:
 1. The Supreme Court ruled that it has jurisdiction to review the matter.
2. The Court upheld the validity of the reorganization of the House representation in the
Commission on Appointments and dismissed the petition.

Ratio:
The Supreme Court held that the issue was justiciable and not merely political, as it involved the legality
of the House's action rather than its wisdom. The Court cited the case of Taada v. Cuenco, which
established that questions of legality, even if involving internal matters of the legislature, are within judicial
review. The Court also referenced its expanded jurisdiction under Article VIII, Section 1, of the 1987
Constitution, which includes the authority to determine whether there has been a grave abuse of
discretion by any branch or instrumentality of the government. The Court found that the reorganization of
the Commission on Appointments was justified by the permanent political realignment resulting from the
formation of the LDP, which had been duly registered as a political party by the Commission on Elections.
The Court dismissed the petition, lifted the temporary restraining order, and affirmed Singson's valid
election to the Commission on Appointments.

5. Bengzon v. Senate Blue Ribbon Committee, 203 SCRA 767

The case "Bengzon Jr. v. Senate Blue Ribbon Committee" involves a petition for prohibition filed by Jose
F.S. Bengzon Jr. and several others against the Senate Blue Ribbon Committee and its members,
represented by Chairman Hon. Wigberto Tañada. The petitioners sought to enjoin the Committee from
requiring them to testify and produce evidence in an inquiry into the alleged sale of corporations owned by
Benjamin "Kokoy" Romualdez to the Lopa Group. This case originates from Civil Case No. 0035 filed by
the Republic of the Philippines, represented by the Presidential Commission on Good Government
(PCGG), against Romualdez and others for reconveyance, reversion, accounting, restitution, and
damages. The petitioners were impleaded as defendants in this case. The Senate Blue Ribbon
Committee's inquiry was initiated following a speech by Senator Juan Ponce Enrile, who called for an
investigation into the alleged takeover of Romualdez's corporations by Ricardo Lopa, President Corazon
Aquino's brother-in-law. The petitioners argued that the inquiry had no valid legislative purpose, was a
purely private transaction, and violated their right to due process. The Supreme Court was tasked with
determining whether the Committee's inquiry was within its jurisdiction and whether it violated the
petitioners' constitutional rights.

Issue:
1. Does the Senate Blue Ribbon Committee's inquiry have a valid legislative purpose, i.e., is it
conducted in aid of legislation?
2. Is the sale or disposition of the Romualdez corporations a purely private transaction beyond the
Committee's power to inquire?
3. Does the inquiry violate the petitioners' right to due process?

Ruling:
1. The Supreme Court ruled that the Senate Blue Ribbon Committee's inquiry did not have a valid
legislative purpose and was not conducted in aid of legislation.
2. The Court held that the sale or disposition of the Romualdez corporations was a matter more
appropriately within the jurisdiction of the courts rather than the legislature.
 3. The Court found that the inquiry violated the petitioners' right to due process, particularly given
that the issues were already being litigated in the Sandiganbayan.

Ratio:
The Supreme Court emphasized that while the power of Congress to conduct inquiries in aid of legislation
is recognized under the 1987 Philippine Constitution, this power is not absolute and must respect the
rights of individuals and the jurisdiction of the judiciary. The Court noted that the inquiry by the Senate
Blue Ribbon Committee was not related to any proposed legislation but was instead aimed at
investigating potential violations of the Anti-Graft and Corrupt Practices Act by private individuals. This
purpose was deemed more appropriate for judicial rather than legislative inquiry. The Court also
highlighted the risk of conflicting judgments between the legislative committee and the judiciary, which
could undermine the judicial process. Additionally, the Court underscored the petitioners' right against
self-incrimination and the need to respect their due process rights, especially since they were already
defendants in an ongoing case before the Sandiganbayan. The Court concluded that allowing the
Committee's inquiry would encroach upon the judiciary's exclusive domain and violate the principle of
separation of powers.

6. Arnault v. Nazareno, 87 Phil. 29

Facts:
The case of "Arnault v. Nazareno" involves Jean L. Arnault, the petitioner, against Leon Nazareno,
Sergeant-at-Arms of the Philippine Senate, and Eustaquio Balagtas, Director of Prisons, as respondents.
The case arose from a Senate investigation into the purchase of the Buenavista and Tambobong estates
by the Philippine Government in October 1949. The government paid a total of P5,000,000 for these
estates, with P1,500,000 going to Ernest H. Burt, a nonresident American, through his attorney-in-fact,
Jean L. Arnault. The Senate, suspecting irregularities and misuse of public funds, created a special
committee to investigate the transactions. Arnault was called to testify and refused to reveal the name of
the person to whom he gave P440,000, claiming he could not remember the name and later invoking his
privilege against self-incrimination. The Senate found him in contempt and ordered his imprisonment until
he disclosed the information. Arnault filed a petition for habeas corpus, challenging the Senate's authority
to detain him.

Issue:
1. Does the Senate have the authority to punish a witness for contempt for refusing to answer
questions pertinent to a legislative inquiry?
2. Can the Senate commit a witness for contempt beyond the period of its legislative session?
3. Does the privilege against self-incrimination protect Arnault from revealing the name of the
person to whom he gave P440,000?

Ruling:
1. Yes, the Senate has the authority to punish a witness for contempt for refusing to answer
questions pertinent to a legislative inquiry.
2. Yes, the Senate can commit a witness for contempt beyond the period of its legislative session.
3. No, the privilege against self-incrimination does not protect Arnault from revealing the name of
the person to whom he gave P440,000.
Ratio:
The Supreme Court ruled that the power of inquiry is essential to the legislative function, and the Senate
has the authority to enforce this power by punishing for contempt. The Court emphasized that the
legislative body must be able to obtain necessary information to legislate effectively. The materiality of the
questions asked by the Senate committee was established, as they were directly related to the
investigation of the Buenavista and Tambobong estates deal, which involved a significant amount of
public funds. The Court also held that the Senate, as a continuing body, has the authority to commit a
witness for contempt beyond the period of its legislative session. This power is necessary to ensure the
completion of legislative investigations and the proper functioning of the legislative process. Regarding
the privilege against self-incrimination, the Court found that Arnault's claim was not justified. The Court
determined that the danger of self-incrimination must be reasonable and real, and in this case, Arnault's
refusal to answer was based on an unfounded and evasive claim. The Court concluded that Arnault's duty
as a citizen to provide truthful testimony outweighed his claimed privilege against self-incrimination.

7. Garcillano v. House of Representatives

Facts:
The case "Garcillano v. House of Representatives Committees on Public Information" involves two
consolidated petitions, G.R. Nos. 170338 and 179275, decided on December 23, 2008. The controversy
centers around the "Hello Garci" tapes, which allegedly contain wiretapped conversations between
then-President Gloria Macapagal-Arroyo and COMELEC Commissioner Virgilio Garcillano, discussing the
manipulation of the 2004 presidential election results. The tapes led to legislative inquiries by both the
House of Representatives and the Senate. In the House, Minority Floor Leader Francis G. Escudero
initiated an investigation on June 8, 2005, which led to the playing of the tapes in the House chambers.
The House Committees later suspended the hearings but decided to prepare committee reports based on
the recordings. Alarmed by these developments, Garcillano filed a petition (G.R. No. 170338) to prohibit
the use of the tapes in the House proceedings. Separately, Senator Panfilo Lacson revived the issue in
the Senate, leading to another legislative inquiry. Petitioners Santiago Javier Ranada and Oswaldo
Agcaoili, along with intervenor Maj. Lindsay Rex Sagge, filed a petition (G.R. No. 179275) to stop the
Senate inquiry, arguing it violated the Anti-Wiretapping Law (R.A. No. 4200) and the Constitution. The
Supreme Court consolidated the cases and heard oral arguments.

Issue:
1. Whether the petitioners have legal standing (locus standi) to bring the suit.
2. Whether the Senate and House of Representatives must republish their Rules of Procedure
Governing Inquiries in Aid of Legislation for each Congress.
3. Whether the legislative inquiries into the "Hello Garci" tapes violate Section 3, Article III of the
Constitution and/or Republic Act No. 4200.

Ruling:
1. The Court recognized the legal standing of the petitioners in both cases.
2. The Court ruled that the Senate must republish its Rules of Procedure Governing Inquiries in Aid
of Legislation for each Congress.
3. The Court dismissed G.R. No. 170338 as moot and academic but granted G.R. No. 179275,
prohibiting the Senate from conducting the inquiry without duly published rules.
Ratio:
1. Legal Standing: The Court acknowledged that Garcillano had a personal stake in the outcome of
the case as he was directly implicated in the "Hello Garci" tapes. Similarly, Ranada, Agcaoili, and
Sagge were recognized for their interest in the execution of laws and their constitutional rights,
satisfying the requirement for legal standing.
2. Publication of Rules: The Court emphasized that Section 21, Article VI of the 1987 Constitution
requires that legislative inquiries be conducted in accordance with duly published rules of
procedure. The Senate's failure to republish its rules at the start of each Congress violated this
constitutional mandate. The Court cited the need for due process and public notice, ruling that the
Senate must republish its rules to ensure transparency and fairness in legislative inquiries.
3. Mootness of G.R. No. 170338: The Court found that the petition filed by Garcillano was moot
because the tapes had already been played in the House, and the committee reports had been
submitted. Prohibition is a preventive remedy and cannot address actions already completed.
4. Violation of R.A. No. 4200: The Court held that the Senate's inquiry into the "Hello Garci" tapes
could not proceed without duly published rules, as required by the Constitution. The Court
underscored that the use of illegally obtained wiretapped communications is prohibited under
R.A. No. 4200, and any legislative inquiry must respect the rights of individuals involved.

The decision reflects the Court's commitment to upholding constitutional mandates and ensuring that
legislative bodies operate within the bounds of the law, particularly concerning due process and the right
to privacy of communication.

8. Senate v. Ermita

Facts:
The case "Senate of the Philippines v. Ermita" involves multiple petitions challenging the constitutionality
of Executive Order No. 464 (E.O. 464), issued by President Gloria Macapagal-Arroyo on September 28,
2005. The petitioners include the Senate of the Philippines, represented by Senate President Franklin M.
Drilon and other senators, as well as various organizations and individuals such as Bayan Muna,
Francisco I. Chavez, and the Integrated Bar of the Philippines. E.O. 464 required heads of executive
departments and other high-ranking officials to secure the President's consent before appearing in
congressional inquiries. The order was issued following a series of Senate investigations into various
issues, including the NorthRail project and alleged wiretapping activities. The Senate had invited several
executive officials to testify, but they were barred from attending due to E.O. 464. The petitioners argued
that the order unduly restricted the power of Congress to conduct inquiries in aid of legislation and
violated the principle of separation of powers. The case was consolidated and brought before the
Supreme Court, which heard oral arguments and received memoranda from the parties involved.

Issue:
1. Does E.O. 464 contravene the power of inquiry vested in Congress?
2. Does E.O. 464 violate the right of the people to information on matters of public concern?
3. Did respondents commit grave abuse of discretion by implementing E.O. 464 prior to its
publication in a newspaper of general circulation?

Ruling:
The Supreme Court partly granted the petitions, declaring Sections 2(b) and 3 of E.O. 464 void, while
upholding the validity of Sections 1 and 2(a). The Court ruled that the requirement for executive officials to
secure the President's consent before appearing in congressional inquiries, as stipulated in Sections 2(b)
and 3, was unconstitutional. However, the Court found that Section 1, which pertains to the appearance of
department heads during the question hour, and Section 2(a), which provides guidelines on executive
privilege, were valid.

Ratio:
The Court's decision was based on several key points. First, it emphasized that the power of inquiry is
inherent in the legislative function and is essential for Congress to legislate wisely and effectively. The
Court noted that while the 1987 Constitution allows for executive privilege, such privilege must be clearly
asserted and justified. The Court found that E.O. 464's provisions allowing for implied claims of executive
privilege were insufficient and invalid, as they did not provide specific reasons for withholding information.
The Court also highlighted the importance of transparency and accountability in a democratic society,
stating that the presumption should always favor disclosure over secrecy. Additionally, the Court ruled that
E.O. 464 should have been published before its implementation, as it directly affected the public's right to
information. The decision underscored the need to balance the executive's confidentiality interests with
the public's right to know and Congress's legislative functions.

9. Guingona v. Carague

Facts:
In the case of "Guingona, Jr. v. Carague," petitioners Teofisto T. Guingona, Jr. and Aquilino Q. Pimentel,
Jr., both Senators of the Republic of the Philippines, challenged the constitutionality of the automatic
appropriation for debt service in the 1990 budget. The respondents were Hon. Guillermo Carague,
Secretary of Budget and Management, Hon. Rozalina S. Cajucom, National Treasurer, and the
Commission on Audit. The 1990 budget included P98.4 billion in automatic appropriations, with P86.8
billion allocated for debt service, and P155.3 billion appropriated under Republic Act No. 6831, the
General Appropriations Act, totaling P233.5 billion. The Department of Education, Culture, and Sports
received P27,017,813,000.00. The automatic appropriation for debt service was authorized by
Presidential Decree (P.D.) No. 81, P.D. No. 1177, and P.D. No. 1967. The petitioners sought to declare
these decrees unconstitutional and to restrain the disbursement for debt service under the 1990 budget.
The respondents argued that the petition involved a political question, which should be addressed by the
legislative body, not the Court.

Issue:
1. Is the appropriation of P86 billion in the P233 billion 1990 budget violative of Section 5, Article
XIV of the Constitution?
2. Are P.D. No. 81, P.D. No. 1177, and P.D. No. 1967 still operative under the 1987 Constitution?
3. Are these decrees violative of Section 29(1), Article VI of the Constitution?

Ruling:
The Supreme Court dismissed the petition, upholding the constitutionality of the automatic appropriation
for debt service in the 1990 budget. The Court ruled that the appropriation did not violate the
constitutional mandate to prioritize education, that the presidential decrees authorizing automatic
appropriations remained operative, and that there was no undue delegation of legislative power.

Ratio:
The Court reasoned that Congress had complied with the constitutional mandate to prioritize education by
allocating the highest budgetary amount to the Department of Education, Culture, and Sports. The
automatic appropriation for debt service was deemed necessary to protect the country's credit standing
and ensure the survival of the economy. The Court found that P.D. No. 81, P.D. No. 1177, and P.D. No.
1967 were consistent with the 1987 Constitution and remained operative until amended, repealed, or
revoked by Congress. The Court also held that the decrees did not constitute an undue delegation of
legislative power, as they provided sufficient standards and parameters for the executive to implement the
appropriations. The Court emphasized that the issue of whether the country should honor its international
debt was a political question for Congress and the Executive to decide.

10. Philconsa v. Enriquez

Facts:
The case "Philippine Constitution Association v. Enriquez" involves multiple petitions consolidated for
resolution by the Philippine Supreme Court. The petitioners include the Philippine Constitution
Association, Exequiel B. Garcia, Ramon A. Gonzales, Raul S. Roco, Neptali A. Gonzales, Edgardo J.
Angara, Wigberto E. Taada, Alberto G. Romulo, and the Freedom from Debt Coalition. The respondents
are Hon. Salvador Enriquez, Secretary of Budget and Management, Hon. Vicente T. Tan, National
Treasurer, and the Commission on Audit (COA). The case revolves around the General Appropriation Act
of 1994 (GAA of 1994), which was passed by Congress and signed into law by the President on
December 30, 1993, becoming Republic Act No. 7663. The President, however, issued a veto message
specifying certain provisions he vetoed or imposed conditions on. The petitioners challenged the
constitutionality of various provisions in the GAA of 1994, including the Countrywide Development Fund,
realignment of operating expenses, and the prioritization of debt service over education. They also
contested the President's vetoes and conditions on specific appropriations, arguing that these actions
exceeded his constitutional authority and encroached on legislative powers. The lower courts did not
override the President's vetoes, leading to the petitions being filed with the Supreme Court.

Issue:
1. Can members of Congress propose and identify projects to be funded by the Countrywide
Development Fund?
2. Is the realignment of operating expenses by individual members of Congress constitutional?
3. Can Congress prioritize debt service over education in the national budget?
4. Is the President's veto of the special provision on debt service valid?
5. Can the President veto specific provisions in the appropriations for State Universities and
Colleges (SUCs), the Department of Public Works and Highways (DPWH), and the Armed Forces
of the Philippines (AFP)?
6. Are the conditions imposed by the President on the appropriations for the Supreme Court, COA,
Ombudsman, and Commission on Human Rights (CHR) valid?

Ruling:
 1. The Supreme Court upheld the constitutionality of the Countrywide Development Fund, allowing
members of Congress to propose and identify projects.
2. The Court ruled that the realignment of operating expenses by individual members of Congress is
constitutional, provided it is approved by the Senate President or the Speaker of the House.
3. The Court held that Congress can prioritize debt service over education, as the constitutional
mandate to prioritize education is directory, not mandatory.
4. The President's veto of the special provision on debt service was upheld, except for the provisos
specifying the use of the fund and prohibiting its use for the liabilities of the Central Bank Board of
Liquidators.
5. The Court upheld the President's veto of specific provisions in the appropriations for SUCs,
DPWH, and AFP, except for the second paragraph of Special Provision No. 2 for DPWH and
Special Provision No. 12 on the purchase of medicines by the AFP.
6. The conditions imposed by the President on the appropriations for the Supreme Court, COA,
Ombudsman, and CHR were deemed valid as they were mere reminders to adhere to existing
laws and regulations.

Ratio:
1. The Court reasoned that the power of appropriation includes the authority to specify projects and
activities to be funded. The proposals and identifications by members of Congress are merely
recommendatory, and the President retains the authority to implement the projects.
2. The realignment of operating expenses is allowed under the Constitution, provided it is done with
the approval of the Senate President or the Speaker of the House, ensuring that the funds are
used appropriately and within the limits of the appropriations.
3. The constitutional mandate to prioritize education is directory, allowing Congress to allocate funds
for debt service if it deems it necessary for the national interest and economic stability.
4. The President's veto power includes the authority to veto specific provisions in an appropriation
bill, especially if they are deemed inappropriate or unconstitutional. The veto of the special
provision on debt service was valid, except for the provisos directly related to the appropriation
item.
5. The veto of specific provisions in the appropriations for SUCs, DPWH, and AFP was justified as
these provisions were either inappropriate or violated existing laws and contractual obligations.
The exceptions were provisions directly related to the appropriations and necessary for their
implementation.
6. The conditions imposed by the President were consistent with his constitutional duty to ensure
that laws are faithfully executed. These conditions did not add new requirements but reinforced
adherence to existing laws and regulations.
 11. Philconsa v. Gimenez

Facts:
The case "Philippine Constitution Association, Inc. v. Gimenez" (G.R. No. L-23326) was decided on
December 18, 1965, by the Philippine Supreme Court en banc. The petitioners were Salvador Araneta,
Guillermo B. Guevara, Pio Pedrosa, Conrado Benitez, Jose M. Aruego, Sotero H. Laurel, Felixberto M.
Serrano, and Roman Ozaeta, represented by Roman Ozaeta, Guillermo B. Guevara, Jose M. Aruego,
Sotero H. Laurel, and Felixberto M. Serrano. The respondents were Pedro M. Gimenez, Jose Velasco,
Eladio Salita, and Jose Aviles, represented by the Solicitor General. The petitioners challenged the
constitutionality of Republic Act No. 3836, which provided retirement benefits for members of Congress.
They argued that the Act violated several constitutional provisions, including the prohibition on salary
increases for members of Congress during their term, the equal protection clause, and the requirement
that bills must have one subject, which must be expressed in the title. The lower courts had upheld the
Act, leading to this appeal.

Issue:
1. Does Republic Act No. 3836 violate the prohibition on salary increases for members of Congress
during their term of office?
2. Does the Act violate the equal protection clause by providing different retirement benefits for
members of Congress compared to other government officials?
3. Does the Act violate the constitutional requirement that bills must have one subject, which must
be expressed in the title?

Ruling:
1. The Supreme Court ruled that Republic Act No. 3836 violated the prohibition on salary increases
for members of Congress during their term of office.
2. The Court found that the Act violated the equal protection clause by providing different retirement
benefits for members of Congress compared to other government officials.
3. The Court also ruled that the Act violated the constitutional requirement that bills must have one
subject, which must be expressed in the title.

Ratio:
1. The Court held that the provision for retirement benefits in Republic Act No. 3836 was essentially
an increase in compensation for members of Congress, which is prohibited by Section 14 of
Article VI of the 1935 Philippine Constitution. The Court reasoned that retirement benefits are a
form of emolument, and any increase in emoluments during a member's term is unconstitutional.
2. On the equal protection issue, the Court found that the Act created a discriminatory classification
by providing more favorable retirement benefits to members of Congress compared to other
government officials. This disparity was deemed arbitrary and without a reasonable basis, thus
violating the equal protection clause.
3. Regarding the requirement for bills to have one subject expressed in the title, the Court found that
the title of Republic Act No. 3836 did not adequately reflect its content. The title did not mention
the provision for retirement benefits for members of Congress, thereby failing to meet the
constitutional requirement.