Constantino v. CuisiaG.R. No. 106064.

October 13, 2005

Facts
: Petition for certiorari, prohibition andmandamus of the Philippine ComprehensiveProgram for
1992.Petitioners are members of the non-government organization, Freedom from DebtCoalition, which
advocates a “pro-people and just Philippine debt policy.” They question the Financing Program started by
then President Corazon Aquino, characterized as a “multi-option financing package”, wherein
thePresident entered into three restructuringagreements with foreign creditor governments.Petitioners
stress that unlike otherpowers which may be validly delegated by thePresident, the power to incur foreign
debts isexpressly reserved by the Constitution in theperson of the President.

Held
: Petition DISMISSED.

Issue
: WON the President can delegate thepower to incur foreign debts to other executiveagencies.
WON the President can borrow to meet publicexpenditures in the form of bonds.

Ratio/Doctrine
: Yes, based on the Doctrine of Qualified Political Agency. Each head of the department is and must be,
the President’s alter ego in the matters of that departmentwhere the President is required by law
toexercise authority. The doctrine of qualified political agency essentially postulates that the heads of
the various executive departments are the alter egos of the President, and, thus, the actions taken by
such heads in the performance of their official duties are deemed the acts of the President unless the
President himself should disapprove such acts

Yes, based on RA 245, as amended byPD 142, s.1973