Primary Holding

The Court held that the post-enactment authority granted to legislators under the PDAF and similar schemes constitutes an impermissible intrusion into the Executive's budget execution domain, and that lump-sum discretionary funds without specific guidelines amount to an undue delegation of legislative power and undermines the President's item-veto power.

Background

The case arose from public outrage and concern over the alleged misuse and corruption associated with the Priority Development Assistance Fund (PDAF) and other lump-sum discretionary funds, particularly in light of the Commission on Audit (CoA) report and the "Napoles controversy."

Facts

• 1. The case centered on the constitutionality of the 2013 PDAF Article and other similar laws, as well as certain Presidential discretionary funds (Malampaya Funds and Presidential Social Fund). The PDAF allowed legislators to identify projects to be funded after the GAA was passed. The CoA Report revealed irregularities in the use of PDAF funds, including instances where funds were released for projects outside legislative districts, transferred to NGOs with questionable backgrounds, and used for infrastructure projects on private land. Whistle-blowers alleged misuse of Malampaya Funds.

Arguments of the Petitioners

• 1. The petitioners argued that the Pork Barrel System, including the 2013 PDAF Article and the Executive's lump-sum discretionary funds, is unconstitutional because it violates the principles of separation of powers, non-delegability of legislative power, checks and balances, accountability, political dynasties, and local autonomy. They asserted that the system allows legislators to unduly interfere with budget execution and gives them unchecked discretionary power.

Arguments of the Respondents

• 1. The respondents contended that the issues are matters of policy not subject to judicial review and that the petitioners lack legal standing. They maintained that the President retains ultimate authority over budget execution and that the legislators' proposals are merely recommendatory, thus not violating the principle of separation of powers. They also argued that lump-sum appropriations are essential for addressing unforeseen circumstances and that the system is constitutional under the Court's previous rulings in Philconsa and LAMP.

Issues

• 1. Whether the consolidated petitions involve an actual and justiciable controversy.
• 2. Whether the issues raised are matters of policy not subject to judicial review.
• 3. Whether petitioners have legal standing to sue.
• 4. Whether Philconsa and LAMP bar the re-litigation of the issue under res judicata and stare decisis.
• 5. Whether the 2013 PDAF Article and similar Congressional Pork Barrel Laws are unconstitutional for violating separation of powers, non-delegability, checks and balances, accountability, political dynasties, and local autonomy.
• 6. Whether phrases in PD 910 (Malampaya Funds) and PD 1869/1993 (Presidential Social Fund) constitute undue delegations of legislative power.

Ruling

• 1. The Court ruled that the 2013 PDAF Article and all other Congressional Pork Barrel Laws similar thereto are unconstitutional because they violate the principles of separation of powers, non-delegability of legislative power, and checks and balances. The Court also found the phrases "and for such other purposes as may be hereafter directed by the President" in Section 8 of PD 910 and Section 12 of PD 1869, as amended by PD 1993, to be unconstitutional insofar as they constitute undue delegations of legislative power. The petitions were partly granted.

Doctrines

• 1. Separation of Powers: The principle that the powers of government are divided among the legislative, executive, and judicial branches to prevent the concentration of power in any one branch.
• 2. Non-delegability of Legislative Power: The principle that legislative power, vested in Congress, cannot be delegated to other bodies or individuals, except for certain recognized exceptions.
• 3. Checks and Balances: The system by which each branch of government can limit the power of the other branches to prevent abuse of power.
• 4. Actual Case or Controversy: The requirement that courts can only exercise judicial power when there is a real dispute between parties involving legal rights.
• 5. Locus Standi: The requirement that a party must have a personal stake in the outcome of a controversy to have the right to bring a lawsuit.
• 6. Political Question Doctrine: The principle that courts should not decide issues that are properly committed to the other branches of government.
• 7. Res Judicata: The principle that a judgment on the merits in a previous case would bind a subsequent case if there exists an identity of parties, of subject matter, and of causes of action.
• 8. Stare Decisis: The principle that a conclusion reached in one case should be applied to those that follow if the facts are substantially the same, even though the parties may be different.

Key Excerpts

• 1. "The 2013 PDAF Article... allowed legislators to individually exercise the power of appropriation, which is vested solely in Congress."
• 2. "Lump-sum appropriations without line-item specifics render the President’s veto power inutile."
• 3. "Experience is the oracle of truth."

Precedents Cited

• 1. Angara v. Electoral Commission: Used to explain the principle of separation of powers.
• 2. Guingona, Jr. v. Hon. Carague: Cited to define the phase of budget execution.
• 3. Abakada Guro Party List v. Purisima: Cited to establish that any post-enactment congressional measure that empowers Congress or its members to play any role in the implementation or enforcement of the law violates the separation of powers principle.
• 4. Bengzon v. Secretary of Justice and Insular Auditor: Used to explain the power of appropriation.
• 5. Philippine Constitution Association v. Enriquez (Philconsa): Discussed in relation to stare decisis and partially abandoned insofar as it validated the post-enactment identification authority of Members of Congress.
• 6. Lawyers Against Monopoly and Poverty v. Secretary of Budget and Management (LAMP): Distinguished as having been dismissed on procedural technicality and not setting any controlling doctrine susceptible of current application to the substantive issues.
• 7. Sanlakas v. Executive Secretary: Invoked the "capable of repetition but evading review" exception to mootness.

Statutory and Constitutional Provisions

• 1. Article VI, Section 1 of the 1987 Constitution: Vesting of legislative power in Congress.
• 2. Article VI, Section 25(4) of the 1987 Constitution: Requirements for special appropriations bills.
• 3. Article VI, Section 25(6) of the 1987 Constitution: Requirements for discretionary funds.
• 4. Article VI, Section 27(2) of the 1987 Constitution: Presidential item-veto power.
• 5. Article VI, Section 29(1) of the 1987 Constitution: No money shall be paid out of the Treasury except in pursuance of an appropriation made by law.
• 6. Article VIII, Section 1 of the 1987 Constitution: Definition of judicial power.
• 7. Presidential Decree No. 910, Section 8: Creation of the Malampaya Funds.
• 8. Presidential Decree No. 1869, Section 12, as amended by PD 1993: Creation of the Presidential Social Fund.
• 9. Act 3044 or the Public Works Act of 1922, Section 3: Early form of "Congressional Pork Barrel".