Primary Holding

The Supreme Court upheld the constitutionality of RA 9335, except for Section 12, which created the Joint Congressional Oversight Committee. The Court ruled that the oversight committee violated the separation of powers doctrine.

Background

RA 9335 was enacted to improve the revenue collection performance of the BIR and BOC by creating a rewards and incentives fund and a Revenue Performance Evaluation Board. The law provides rewards for exceeding revenue targets and sanctions for failing to meet them. Petitioners, representing the Abakada Guro Party List, filed a petition challenging the constitutionality of the law, arguing that it violated several constitutional principles.

Facts

• 1. RA 9335 established a system of rewards and sanctions for BIR and BOC officials and employees based on their revenue collection performance. The law created a Rewards and Incentives Fund sourced from excess collections and a Revenue Performance Evaluation Board to oversee the implementation. The law also created a Joint Congressional Oversight Committee to approve the implementing rules and regulations (IRR).

Arguments of the Petitioners

• 1. RA 9335 established a system of rewards and sanctions for BIR and BOC officials and employees based on their revenue collection performance. The law created a Rewards and Incentives Fund sourced from excess collections and a Revenue Performance Evaluation Board to oversee the implementation. The law also created a Joint Congressional Oversight Committee to approve the implementing rules and regulations (IRR).

Arguments of the Respondents

• 1. The petition is premature as there is no actual case or controversy.
• 2. The reward system does not breed corruption and is a valid classification under the equal protection clause.
• 3. The law provides sufficient standards for the President to set revenue targets.
• 4. The congressional oversight committee enhances, rather than violates, the separation of powers by ensuring legislative policy is fulfilled.

Issues

• 1. Whether the petition is ripe for adjudication.
• 2. Whether RA 9335 violates the equal protection clause.
• 3. Whether RA 9335 unduly delegates legislative power to the President.
• 4. Whether the creation of the Joint Congressional Oversight Committee violates the separation of powers.

Ruling

• 1. The Court found the petition procedurally infirm due to lack of ripeness but addressed the constitutional issues due to public interest.
• 2. The Court upheld the constitutionality of RA 9335, except for Section 12, which created the Joint Congressional Oversight Committee.
• 3. The Court ruled that the rewards and sanctions system does not violate the equal protection clause as it is based on a valid classification.
• 4. The Court found that the law provides sufficient standards for the President to set revenue targets, thus not unduly delegating legislative power.
• 5. The Court declared the Joint Congressional Oversight Committee unconstitutional as it violated the separation of powers by allowing legislative participation in the implementation of the law.

Doctrines

• 1. Presumption of Constitutionality: Laws are presumed constitutional unless proven otherwise.
• 2. Equal Protection Clause: The law must apply equally to all persons similarly situated.
• 3. Separation of Powers: Each branch of government must remain within its constitutional limits.
• 4. Undue Delegation of Legislative Power: The legislature cannot delegate its power without providing sufficient standards.

Key Excerpts

• 1. "Public office is a public trust. Public officers and employees must at all times be accountable to the people, serve them with utmost responsibility, integrity, loyalty, and efficiency."
• 2. "The offer of a portion of such penalties to the collectors is to stimulate and reward their zeal and industry in detecting fraudulent attempts to evade payment of duties and taxes."

Precedents Cited

• 1. United States v. Matthews: Cited to support the validity of reward systems for government officials.
• 2. Immigration and Naturalization Service v. Chadha: Cited to support the unconstitutionality of legislative vetoes.
• 3. Macalintal v. COMELEC: Cited to discuss the concept of congressional oversight and its limits.

Statutory and Constitutional Provisions

• 1. Article II, Section 1: Public office as a public trust.
• 2. Article III, Section 1: Equal protection clause.
• 3. Article VI, Section 27: Presentment clause.
• 4. RA 9335, Sections 2, 4, 7, 12: Provisions of the Attrition Act of 2005.