Sameer Overseas Placement vs Cabiles

Respondent Joy Cabiles worked as a cutter for Taiwan Wacoal, Co, Ltd (Wacoal) through petitioner Sameer Overseas Placement, Inc.,
a recruitment and placement agency. In less than a month, respondent was terminated without prior notice and was repatriated.
Respondent filed a case for her illegal dismissal. The National Labor Relations Commission awarded respondent only three (3) month
worth of salary, reimbursement of withheld repatriation expense and attorney’s fee. The award was based on Section 7 of RA 10022,
which is an amendment of Section 10 of RA 8042 Migrant Workers and Overseas Filipinos Act of 1995.

Issue: Is it within the ambit of legislative power when Congress re-enacted the “or for three (3) months for every year of the unexpired
term, whichever is less” clause of RA 8042--- which was already declared unconstitutional?

Ruling: No. The clause "or for three (3) months for every year of the unexpired term, whichever is less" was already declared
unconstitutional for violating the equal protection clause and substantive due process. The nullity cannot be cured by reincorporation
or reenactment of the same or a similar law or provision unless circumstances have so changed as to warrant a reverse conclusion.

Belgica vs Alcantara

“Pork Barrel” refers to an appropriation of government spending meant for localized projects and secured solely or primarily to bring
money to representative’s district. Act 3044, or the Public Works Act of 1922, is considered as the earliest form of "Congressional Pork
Barrel" in the Philippines since the utilization of the funds appropriated therein were subjected to post-enactment legislator approval.
On August 16, 2013, the Commission on Audit (CoA) released the results of a three-year audit investigation covering the use of
legislators' PDAF from 2007 to 2009. Spurred in large part by the findings contained in the CoA Report and the Napoles controversy,
several petitions were lodged before the Court seeking that the "Pork Barrel System” be declared unconstitutional.

Issue: Are post enactment measures which govern the areas of project identification, fund release and fund realignment not related
to functions of congressional oversight and not violative of separation of powers?

Ruling: The post enactment measures are NOT related to functions of congressional oversight. Congressional oversight must be
confined to the (1) scrutiny based primarily on Congress‘ power of appropriation and the budget hearings conducted in connection
with it…; and (2) investigation and monitoring of the implementation of laws pursuant to the power of Congress to conduct inquiries
in aid of legislation. Any action or step beyond that will undermine the separation of powers guaranteed by the Constitution.
Hence, post-enactment features dilute congressional oversight and VIOLATE Section 14, Article VI of the 1987 Constitution.

Issue: Are these measures violative of the non-delegability of legislative functions?

Ruling: YES. The principle of non-delegability should not be confused as a restriction to delegate rule-making authority to implementing
agencies for the limited purpose of either filling up the details of the law for its enforcement (supplementary rule-making) or
ascertaining facts to bring the law into actual operation (contingent rule-making). In the case at bar, the post-enactment identification
authority to individual legislators violates the principle of non-delegability since said legislators are effectively allowed to individually
exercise the power of appropriation, which is lodged in Congress. The power to appropriate must be exercised only through legislation
is clear from Article VI of the 1987 Constitution.

CoTesCUP vs Sec. of Education

To be at par with international standards and in line with the country's commitment in EFA 2015, the Philippine Congress, on May 15,
2013, passed the K to 12 Law, which took effect on June 8, 2013. The K to 12 Law imposes upon the DepEd, CHED, and TESDA, the task
to promulgate the implementing rules and regulations, which shall provide, among others, appropriate strategies and mechanisms to
ensure the smooth transition from the existing 10-year basic education cycle to the K to 12 cycle. The Law was implemented in parts.
DO No. 31 was issued setting forth policy guidelines in the implementation and CMO No. 20 was issued to provide the framework and
rationale of the revised curriculum.

Issue: Whether or not the K to 12 Law was duly enacted?

Ruling: YES. It was enacted in accordance with the procedure prescribed in the Constitution. There were regional consultations and
hearings made. It was passed by the Senate and House of Representatives on January 20, 2013, approved by the President on May 15,
2013, and, after publication, took effect on June 8, 2013.

Issue: Is there undue delegation of legislative power in the enactment of the K to 12 Law?
NO. In determining whether or not a statute constitutes an undue delegation of legislative power, the Court has adopted two tests:
the completeness test and the sufficient standard test. Under the first test, the law must be complete in all its terms and conditions.
The sufficient standard test mandates adequate guidelines or limitations in the law. In the case at bar, the K to 12 Law adequately
provides the legislative policy that it seeks to implement. Moreover, scattered throughout the K to 12 Law are the standards to guide
the DepEd, CHED and TESDA in carrying out the provisions of the law.

Grande vs. Antonio

Facts: Out of the illicit relationship of the petitioner and respondent, two sons were born. When their relationship turned sour, Grande
left for the United States with her two children. This prompted respondent Antonio to file a petition for custody which was granted
by the RTC. Petitioner Grande then filed an appeal with the CA attributing grave error on the part of the RTC. The appellate court,
however, maintained that the legal consequence of the recognition made by respondent Antonio that he is the father of the minors
compels the use by the children of the surname "ANTONIO."

Issue: Are Rule 7 and Rule 8 of the Office of the Civil Registrar Gen. Adm. Order No. 1, Series of 2004 insofar as they provide the
mandatory use by illegitimate children of their father’s surname upon the latter’s recognition of his paternity, accurate and correct
interpretation of Art. 176 of the Family Code, as amended by RA 9255?

Ruling: NO. The use of the word "shall" in the IRR of RA 9255 is of no moment. The clear, unambiguous, and unequivocal use of "may"
in Art. 176 shows that an acknowledged illegitimate child is under no compulsion to use the surname of his illegitimate father. The
word “may” is permissive and operates to confer discretion.

Cawad vs. Abad

On March 26, 1992, Republic Act (RA) No. 7305, otherwise known as The Magna Carta of Public Health Workers was signed into law.
Accordingly, public health workers (PHWs) were granted the following allowances and benefits, among others: hazard allowance,
subsistence allowance, longevity pay, laundry allowance and remote assignment allowance. Respondents DBM and CSC issued DBM-
CSC Joint Circular No. 1, Series of 2012, to prescribe the rules on the grant of Step Increments due to meritorious performance and
Step Increment due to length of service. Shortly thereafter, respondents DBM and DOH circulated DBM-DOH Joint Circular No. 1,
Series of 2012. On January 23, 2013, petitioners expressed their opposition to the Joint Circular on the ground that the same diminishes
the benefits granted by the Magna Carta to PHWs.

Issue: Whether or not respondents’ issuance of DBM-DOH joint circular no. 1, s. 2012 is null and void for being an undue exercise of
legislative power?

Ruling: Partly. The DBM-DOH cannot be said to have been issued with grave abuse of discretion for not only are they reasonable, they
were likewise issued well within the scope of authority granted to the respondents. In fact, except for provision on the lowering the
hazard pay at rates below the minimum prescribed by Section 21 of RA 7305 and Section 7.1.5 of its Revised IRR, the circular did not
make any substantial deviation therefrom, but actually remained consistent with, and germane to, the purposes of the law.

Quezon City PTCA vs. DepEd

On June 1, 2009, the Department of Education issued Department Order No. 54 Revised Guidelines Governing Parents-Teachers
Associations (PTAs) at the School Level which sought to address the limitations of the guidelines set forth in D.O. No. 23 and in
response to increasing reports of malpractices by officers or members of PTAs. Petitioner Quezon City PTCA Federation filed the
present Petition in the belief the provisions undermine the independence of PTAs and PTCAs, effectively amend the constitutions and
by-laws of existing PTAs and PTCAs, and violate its constitutional rights to organize and to due process, as well as other existing laws.

Issue: What is subordinate legislation?

Ruling: Subordinate legislation is the rule-making power of agencies tasked with the administration of government. The national
legislature has found it more and more necessary to entrust to administrative agencies the authority to issue rules to carry out the
general provisions of the statute.

Issue: Is DepEd Order No. 54, s. 2009, an invalid exercise of the rule-making power delegated to the Secretary of Education?
Ruling: No. Department Order No. 54, Series of 2009 was validly issued by the Secretary of Education pursuant to his statutorily vested
rule-making power and pursuant to the purposes for which the organization of parent-teacher associations is mandated by statute.
Likewise, there was no fatal procedural lapse in the adoption of Department Order No. 54, Series of 2009. Chapter 2 of the
Administrative Code provides for the rule-making power of the secretaries heading the departments that comprise the executive
branch of government.
Atong Paglaum vs. Comelec

Approximately 280 groups and organizations registered and manifested their desire to participate in the 13 May 2013 party-list
elections. Fifty two (52) groups were disqualified either by denial of their petitions for registration under the party-list system, or
cancellation of their registration and accreditation as party-list organizations. One of the petitioner was denied participation in the 13
May 2013 party-list elections because it does not represent any "marginalized and underrepresented" sector; it failed to apply for
registration as a party-list group; and it failed to establish its track record as an organization that seeks to uplift the lives of the
"marginalized and underrepresented."

Issue: Does the party-list system include only sectoral parties?

Ruling: No. The framers of the 1987 Constitution expressly rejected the proposal to make the party-list system exclusively for sectoral
parties only, and that they clearly intended the party-list system to include both sectoral and non-sectoral parties. This is clearly
written in Section 5(1), Article VI of the Constitution which states that the party-list system is composed of three different groups: (1)
national parties or organizations; (2) regional parties or organizations; and (3) sectoral parties or organizations.

Issue: Should national and regional parties or organizations represent the “marginalized and underrepresented” sectors?

Ruling: No. There is no requirement in R.A. No. 7941 that a national or regional political party must represent a "marginalized and
underrepresented" sector. It is sufficient that the political party consists of citizens who advocate the same ideology or platform, or
the same governance principles and policies, regardless of their economic status as citizens.

Issue: Must the nominees of the party-list group either belong to the sector, or must have a track record of advocacy for the sector
represented?

Ruling: Yes. The nominees of the sectoral party either must be a bona-fide member or must have a track record of advocacy for the
sector represented. Its track record must speak of its firm advocacy towards uplifting the marginalized and underrepresented by
undertaking activities or projects directly addressing the concerns of the sector.

Issue: Can major political parties participate in party-list elections?

Ruling: Yes. Major political parties can participate in subsequent party-list elections since the prohibition is expressly limited only to
the 1988 party-list elections. However, major political parties should participate in party-list elections only through their sectoral
wings.

Trillanes vs. Judge Marigomen

Petitioner alleged that former Makati Vice Mayor Ernesto Mercado (Mercado) testified on how he helped former Vice President
Jejomar Binay (VP Binay) acquire and expanded the so called “Hacienda Binay.” Petitioner averred that private respondent thereafter
claimed "absolute ownership" of the estate through a Memorandum of Agreement (MOA) with a certain Laureano R. Gregorio, Jr.
(Gregorio, Jr.), the alleged owner of the consolidated estate and its improvements. Petitioner admitted that during media interviews
at the Senate, particularly during gaps and breaks in the plenary hearings as well as committee hearings, he expressed his opinion that
based on his office's review of the documents, private respondent appears to be a "front" or "nominee" or is acting as a "dummy" of
the actual and beneficial owner of the estate, VP Binay. Private respondent filed a complaint and alleged that he is a legitimate business
man.

Issue: Are the statements of Trillanes been made in the course of the performance of his duties as a Senator and, thus, are covered by
his parliamentary immunity?

Ruling: No. Parliamentary non-accountability cannot be invoked when the lawmaker's speech or utterance is made outside sessions,
hearings or debates in Congress, extraneous to the "due functioning of the (legislative) process." A lawmaker's participation in media
interviews is not a legislative act, but is "political in nature," outside the ambit of the immunity conferred under the Speech or Debate
Clause in the 1987 Constitution. In the case at bar, petitioner cannot successfully invoke parliamentary nonaccountability to insulate
his statements, uttered outside the "sphere of legislative activity."
Atty. Lico vs. Comelec

Ating Koop is a multi-sectoral party-list organization which was registered on 16 November 2009 under Republic Act (R.A.) No. 7941,
also known as the Party-List System Act (Party-List Law). It filed with the COMELEC the list of its nominees, with petitioner Lico as first
nominee and Roberto Mascarina as second nominee. Under the term-sharing agreement issued by Ating Koop, petitioner Lico was to
serve as Party-list Representative for the first year of the three-year term. Almost one year after petitioner Lico had assumed office,
the Interim Central Committee expelled him from Ating Koop for disloyalty.

Issue: Who has jurisdiction over the expulsion of a sitting party list member from Congress and from his organization?

Ruling: Section 17, Article VI of the 1987 Constitution endows the HRET with jurisdiction to resolve questions on the qualifications of
members of Congress. In this case, the COMELEC proclaimed Ating Koop as a winning party-list group; petitioner Lico took his oath;
and he assumed office in the House of Representatives. Thus, it is the HRET, and not the COMELEC, that has jurisdiction over the
disqualification case.

Delgado vs. HRET

On 16 September 2008, the Court promulgated its Decision in "Tulfo v. People of the Philippines," convicting Pichay by final judgment
of four counts of libel. On 31 May 2013, Ty-Delgado filed an ad cautelam petition for quo warranto before the HRET reiterating that
Pichay is ineligible to serve as Member of the House of Representatives. The HRET held that it had jurisdiction over the present quo
warranto petition since it involved the eligibility of a Member of the House of Representatives due to a disqualification under Section
12 of the Omnibus Election Code. However, the HRET held that there is nothing in Tulfo v. People of the Philippines which found that
Pichay directly participated in any way in writing the libelous articles, thus concluding that the circumstances surrounding Pichay's
conviction for libel showed that the crime did not involve moral turpitude.

Issue: As the sole judge of the election, returns, and qualifications of the members of the House of Representatives, can the judgment
of the HRET be reviewed?

Ruling: Yes. While it is well-recognized that the HRET has been empowered by the Constitution to be the "sole judge" of all contests
relating to the election, returns, and qualifications of the members of the House of Representatives, the Court maintains jurisdiction
over it to check "whether or not there has been grave abuse of discretion amounting to lack or excess of jurisdiction" on the part of
the latter.

Issue: Did HRET commit grave abuse of discretion?

Ruling: Yes. The HRET committed grave abuse of discretion amounting to lack of or excess of jurisdiction when it failed to disqualify
Pichay for his conviction for libel, a crime involving moral turpitude. In other words, when the HRET utterly disregards the law and
settled precedents on the matter before it, it commits grave abuse of discretion.

Abayon vs. Daza

Abayon and Daza were contenders for the position of Representative in the First Legislative District of Northern Samar during the May
13, 2013 Elections. Abayon emerged as the winner after obtaining the majority vote of 72,857, while Daza placed second with a total
of 72,805 votes. The HRET annulled the election results in five ( 5) clustered precincts in the municipalities of Lavezares and Victoria
because of the commission of massive terrorism. As a result of nullifying the election results in the said clustered precincts, the HRET
deducted the votes received by the parties in the concerned clustered precincts and concluded that Daza obtained 72,436 votes and
Abayon had 72,002 votes. The HRET ratiocinated that there was clear and convincing evidence to warrant the annulment of the
elections in the concerned precincts because the terrorism affected more than 50% of the votes cast in the said precincts and it was
impossible to distinguish the good votes from the bad.

Issue: Does the HRET have the power to annul election results on the ground of terrorism?

Ruling: Yes. Article VI, Section 17 of the Constitution, “the Senate and the House of Representatives shall each have an Electoral
Tribunal which shall be the sole judge of all contests relating to the election, returns, and qualifications of their respective
Members…” The phrase "election, returns and qualifications" should be interpreted in its totality as referring to all matters affecting
the validity of the contestee' s title. The HRET, as the sole judge of all contests relating to the election, returns and qualifications of
members of the House of Representatives, may annul election results if in its determination, fraud, terrorism or other electoral
irregularities existed to warrant the annulment. The power of the HRET to annul elections differ from the power granted to the
COMELEC to declare failure of elections.

Issue: Was there legal basis for the HRET to annul the election results?

Ruling: No. Daza's three (3) witnesses alone are insufficient to prove that indeed terrorism occurred in the contested precincts and
the same affected at least 50% of the votes cast therein. The unsubstantiated testimonies of the witnesses falter when faced with
official pronouncements of government agencies. The decision of the HRET was clearly unsupported by clear and convincing evidence.
Thus, the HRET committed grave abuse of discretion in annulling the elections in the contested precincts.

Lagman vs. Pimentel

On May 23, 2017, President Rodrigo Roa Duterte issued Proclamation No. 216, declaring a state of martial law and suspending the
privilege of the writ of habeas corpus in the whole of Mindanao for a period not exceeding sixty (60) days, to address the rebellion
mounted by members of the Maute Group and Abu Sayyaf Group (ASG). On July 18, 2017, the President requested the Congress to
extend the effectivity of Proclamation No. 216. Acting on the recommendations of the AFP Chief of Staff, General Guerrero, and
Secretary Lorenzana, another request was granted which further extended the period of martial law and suspension of the privilege
of the writ of habeas corpus in the entire Mindanao for one year, from January 1, 2018 to December 31, 2018.

Issue: Is the manner in which Congress deliberated on the President’s request for extension subject to judicial review?

Ruling: No. The manner in which Congress deliberated on the President's request for extension is not subject to judicial review. The
Court's judicial review of the Congress' extension of such proclamation or suspension is limited only to a determination of the
sufficiency of the factual basis thereof. Also, legislative rules do not have the imprints of permanence and obligatoriness during their
effectivity. Being merely matters of procedure, their observance are of no concern to the courts.

Reyes vs. HRET

Petitioner alleges that she has two pending quo warranto cases before the HRET. On 1 November 2015, the HRET published the 2015
Revised Rules of the House of Representatives Electoral Tribunal (2015 HRET Rules). Petitioner alleges that Rule 6 of the 2015 HRET
Rules is unconstitutional as it gives the Justices, collectively, denial or veto powers over the proceedings by simply absenting
themselves from any hearing. Petitioner likewise alleges that Rule 15, in relation to Rules 17 and 18, of the 2015 HRET Rules
unconstitutionally expanded the jurisdiction of the Commission on Elections (COMELEC). Petitioner alleges that the application of the
2015 HRET Rules to all pending cases could prejudice her cases before the HRET.

Issue: Whether or not Rule 6(a), Rule 15, and Rule 6, in relation to Rule 69 of the 2015 HRET Rules are constitutional?

Ruling:
Yes. Rule 6(a) of the 2015 HRET Rules does not make the Justices indispensable members to constitute a quorum but ensures that
representatives from both the Judicial and Legislative departments are present to constitute a quorum. It does not violate the equal
protection clause of the Constitution since the clause allows classification. In the case at bar, there is a substantial distinction between
the Justices of the Supreme Court and the members of the House of Representatives.

Yes. In Rule 15, the HRET is the sole judge of all contests relating to the election, returns, and qualifications of the members of the
House of Representatives. HRET's jurisdiction is provided under Section 17, Article VI of the 1987 Constitution. There is no room for
the COMELEC to assume jurisdiction because HRET's jurisdiction is constitutionally mandated.

Yes. Rule 6 of the 2015 HRET Rules does not grant additional powers to the Justices but rather maintains the balance of power between
the members from the Judicial and Legislative departments as envisioned by the framers of the 1935 and 1987 Constitutions. The
presence of the three Justices is meant to tone down the political nature of the cases involved and do away with the impression that
party interests play a part in the decision-making process.

Balag vs. Senate of the Philippines

On September 17, 2017, Horacio Tomas T. Castillo III, a first year law student of the University of Sto. Tomas (UST), died allegedly due
to hazing conducted by the Aegis Juris Fraternity (AJ Fraternity) of the same university. On September 20, 2017, Senator Paolo Benigno
Aquino IV filed "A Resolution Directing the Appropriate Senate Committees to Conduct An Inquiry, In Aid of Legislation, into the Recent
Death of Horacio Tomas Castillo III Allegedly Due to Hazing-Related Activities." On October 18, 2017, petitioner attended the senate
hearing. The committee asked him questions but he refused to answer and instead, he invoked his right against self-incrimination.
Petitioner had numerous opportunities to answer the questions of the committee but he refused to do so. Senator Poe then moved
to cite him in contempt, and the Senate Sergeant-at-arms was ordered to place petitioner in detention after the committee hearing.

Issue: Being a continuing body, can the Senate indefinitely detain a person held in contempt in connection with its investigation in aid
of legislation?

Ruling: No. Section 21, Article VI of the Constitution states that Congress, in conducting inquiries in aid of legislation, must respect the
rights of persons appearing in or affected therein. The Senate can continuously and effectively exercise its power of contempt during
the legislative inquiry, but if the Congress decides to extend the period of imprisonment for the contempt committed by a witness
beyond the duration of the legislative inquiry, then it may file a criminal case under the existing statute or enact a new law to increase
the definite period of imprisonment.

Agcaoili vs. Fariñas

On March 14, 2017, House Resolution No. 882 was introduced by respondent Fariñas directing House Committee to conduct an inquiry
pertaining to the use by the Provincial Government of Ilocos Norte of its shares from the excise taxes on locally manufactured virginia-
type cigarettes for a purpose other than that provided for by Republic Act (R.A.) No. 7171. Invitation Letters dated April 6, 2017 were
individually sent to petitioners for them to attend as resource persons. Petitioners allege that at the hearing, they were subjected to
threats and intimidation. On the other hand, respondents aver that petitioners were evasive in answering questions and simply
claimed not to remember the specifics of the subject transactions. Co-petitioner Marcos assails the nature of the legislative inquiry is
a fishing expedition in violation of petitioners' right to due process and is allegedly discriminatory to the Province of Ilocos Norte.
Respondents counter that a petition for prohibition is not the proper remedy to enjoin legislative actions.

Issue: Whether or not the subject legislative inquiry on House Resolution No. 882 may be enjoined by a writ of prohibition?

Ruling: Yes. Prohibition is not the proper remedy but an ordinary action for nullification, over which the Court generally exercises not
primary, but appellate jurisdiction. While there is no question that a writ of prohibition lies against legislative functions, the Court
finds no justification for the issuance thereof in the instant case. the exercise of the power of inquiry is such that the investigation
must be "in aid of legislation in accordance with its duly published rules of procedure" and that "the rights of persons appearing in or
affected by such inquiries shall be respected."

Araulo vs. Aquino, G.R. No. 209287, Feb. 03, 2015

The respondents maintain that the issues in these consolidated cases were mischaracterized and unnecessarily constitutionalized;
that the Court’s interpretation of savings can be overturned by legislation; that the withdrawn unobligated allotments and unreleased
appropriations constitute savings and may be used for augmentation; and that the Court should apply legally recognized norms and
principles in resolving their motion. On their part, the petitioners in G.R. No. 209442 pray for the partial reconsideration of the
decision. They submit that augmentation of items beyond the maximum amounts recommended by the President for the programs,
activities and projects (PAPs) contained in the budget submitted to Congress should be declared unconstitutional.

Issue: Is “savings”, as a concept, an ordinary species of interpretation that calls for legislative, instead of judicial, determination?

Ruling: No. The Legislative department is assigned the power to make and enact laws, but the interpretation and application of said
laws belong exclusively to the Judicial department. And this authority to interpret and apply the laws extends to the Constitution. The
interpretation of the GAA and its definition of savings is a foremost judicial function. This is because the power of judicial review vested
in the Court is exclusive.

Issue: Can the power to augment be used to fund non-existent provisions in the GAA?

Ruling: No. There must be an existing item, project or activity, purpose or object of expenditure with an appropriation to which savings
may be transferred for the purpose of augmentation. So long as there is an item in the GAA for which Congress had set aside a specified
amount of public fund, savings may be transferred thereto for augmentation purposes. The power to augment is not the authority to
create new items not found in the appropriations act.
Issue: Does the prohibition against cross-border transfer apply to appropriation and not to savings?

Ruling: No. In Section 25, Article VI of the Constitution, “No law shall be passed authorizing any transfer of appropriations…”
Unobligated allotments, on the other hand, were encompassed by the first part of the definition of "savings" in the GAA, that is, as
"portions or balances of any programmed appropriation in this Act free from any obligation or encumbrance." They can transfer
savings only to “augment” items in their appropriations.

Issue: In an appropriation measure, is there is constitutional requirement for Congress to create allotment classes within an item?

Ruling: No. There is no constitutional requirement for Congress to create allotment classes within an item. What is required is for
Congress to create items to comply with the line-item veto of the President.

Imbong vs. Ochoa

Republic Act (R.A.) No. 10354, otherwise known as the Responsible Parenthood and Reproductive Health Act of 2012 (RH Law), was
enacted by Congress on December 21, 2012. The RH Law is an enhancement measure to fortify and make effective the current laws
on contraception, women's health and population control. It is geared towards the reduction of the country's population. While it
claims to save lives and keep our women and children healthy, it also promotes pregnancy-preventing products. It emphasizes the
need to provide Filipinos, especially the poor and the marginalized, with access to information on the full range of modem family
planning products and methods.

Issue: Does R.A. No. 10354, “The Responsible Parenthood and Reproductive Health Act of 2012, violate Sec. 26(1), Article VI of the
1987 Constitution on the “one subject-one title” rule?

Ruling: No. The rule is sufficiently complied with if the title is comprehensive enough as to include the general object which the statute
seeks to effect. In this case, a textual analysis of the various provisions of the law shows that both "reproductive health" and
"responsible parenthood" are interrelated and germane to the overriding objective to control the population growth. The whole idea
of contraception pervades the entire RH Law. It is, in fact, the central idea of the RH Law.
Araulo vs. Aquino

On September 25, 2013, Sen. Jinggoy Ejercito Estrada delivered a privilege speech in the Senate of the Philippines to reveal that some
Senators, including himself, had been allotted an additional ₱50 Million each as "incentive" for voting in favor of the impeachment of
Chief Justice Renato C. Corona. Responding to Sen. Estrada’s revelation, Secretary Florencio Abad of the DBM (Department of Budget
and Management) issued a public statement entitled Abad: Releases to Senators Part of Spending Acceleration Program, explaining
that the funds released to the Senators had been part of the DAP(Disbursement Acceleration Program), a program designed by the
DBM to ramp up spending to accelerate economic expansion.
He explained that the funds under the DAP were usually taken from (1) unreleased appropriations under Personnel Services; (2)
unprogrammed funds; (3) carry-over appropriations unreleased from the previous year; and (4) budgets for slow-moving items or
projects that had been realigned to support faster-disbursing projects.

Issue: Is a law required to adopt or implement the Disbursement Acceleration Program?

Ruling:
No. No law was necessary for the adoption and implementation of the DAP because of its being neither a fund nor an appropriation,
but a program or an administrative system of prioritizing spending. The adoption of the DAP was by virtue of the authority of the
President as the Chief Executive to ensure that laws were faithfully executed. The DAP was a government policy or strategy designed
to stimulate the economy through accelerated spending.

Issue: Are unreleased appropriations and withdrawn unobligated allotments under the DAP savings?

Ruling:
No. Unreleased appropriations refer to appropriations with allotments but without disbursement authority. For us to consider
unreleased appropriations as savings would seriously undercut the congressional power of the purse, because such appropriations
had not even reached and been used by the agency concerned vis-à-vis the PAPs for which Congress had allocated them.
Unobligated allotments were encompassed by the first part of the definition of "savings" in the GAA. However, it could not be
indiscriminately declared as savings without first determining whether any of the three instances in the GAA’s definition existed. In
other words, savings could be generated only upon the purpose of the appropriation being fulfilled, or upon the need for the
appropriation being no longer existent. The fact that the withdrawn allotments could be "reissued for the original programs and
projects of the agencies/OUs concerned, from which the allotments were withdrawn"supported the conclusion that the
PAPs(program, activity or project) had not yet been finally discontinued or abandoned. Thus, the purpose for which the withdrawn
funds had been appropriated was not yet fulfilled rendering the declaration of the funds as savings impossible.

Issue: Are cross border transfers, constitutionally permissible? Did the DAP violate the prohibition against cross-border transfers?

Ruling:
No. Cross-border transfers, whether as augmentation, or as aid, were prohibited under Section 25(5). The cross-border transfers of
the savings of the Executive to augment the appropriations of other offices outside the Executive is unconstitutional. The provisions
of the GAAs of 2011 and 2012 were textually unfaithful to the Constitution for not carrying the phrase "for their respective offices"
contained in Section 25(5). The impact of the phrase "for their respective offices" was to authorize only transfers of funds within their
offices.
Yes. DAP violated the prohibition against cross border transfers. The transfer of funds amounting to ₱143,700,000.00 and
₱250,000,000.00 constituted cross-border augmentations for being from the Executive to the COA and the House of Representatives.
Regardless of the variant characterizations of the cross-border transfers of funds, the plain text of Section 25(5), disallowing cross
border transfers was disobeyed.

Issue: Was the sourcing of the DAP from unprogrammed funds despite the original revenue targets not having been exceeded, valid?

Ruling:
No. The requirement that revenue collections must exceed revenue target should be understood to mean that the revenue collections
must exceed the total of the revenue targets stated in the BESF. Moreover, to release the unprogrammed funds simply because there
was an excess revenue as to one source of revenue would be an unsound fiscal management measure because it would disregard the
budget plan and foster budget deficits, in contravention of the Government’s surplus budget policy. The funding of projects, activities
and programs that were not covered by any appropriation in the General Appropriations Act is unconstitutional.
La Suerte Cigarette vs. CIR

These cases involve the taxability of stemmed leaf tobacco imported and locally purchased by cigarette manufacturers for use
as raw material in the manufacture of their cigarettes. Under the National Internal Revenue Code of 1997, stemmed leaf
tobacco is subject to an excise tax of P0.75 for each kilogram thereof and that "leaf tobacco which has had the stem or midrib
removed…may be sold in bulk as raw material by one manufacturer directly to another without payment of the tax…”
On January 3, 1990, La Suerte received a letter from then Commissioner Jose U. Ong demanding the payment of the deficiency
of tax, which they protested stressing that the BIR assessment was based solely on Section 141(b) of the Tax Code without
applying Section 137 which expressly allows the sale of stemmed leaf tobacco as raw material by one manufacturer directly to
another without payment of the excise tax. However, Commissioner Jose U. Ong denied La Suerte’s protest, insisting that
stemmed leaf tobacco is subject to excise tax "unless there is an express grant of exemption from [the] payment of tax."

Issue:
Whether the imposition of excise tax on stemmed leaf tobacco under Section 141 of the 1986 Tax Code constitutes double
taxation?

Ruling:
No. For double taxation in the objectionable or prohibited sense to exist, "the same property must be taxed twice, when it
should be taxed but once…Both taxes must be imposed on the same property or subject- matter, for the same purpose, by the
same. . . taxing authority, within the same jurisdiction or taxing district, during the same taxing period, and they must be the
same kind or character of tax."
Section 141 reveals the legislative policy to tax all forms of manufactured tobacco, and stemmed leaf tobacco is subject to the
specific tax under it because it is a partially prepared tobacco. The exemption from the taxability of stemmed leaf tobacco
found in Section 137 is qualified by and is subject to "such conditions as may be prescribed in the regulations of the Department
of Finance." Thus, Section 137 must be read and interpreted in accordance with these regulations (RR Nos. V-39 and 17-67).
In this case, there is no double taxation in the prohibited sense because the specific tax is imposed by explicit provisions of
the Tax Code on two different articles or products: (1) on the stemmed leaf tobacco; and (2) on cigar or cigarette.

Carpio-Morales vs. Binay

A complaint/affidavit was filed by Atty. Renato L. Bondal and Nicolas "Ching" Enciso VI before the Office of the Ombudsman
against Binay, Jr. and other public officers and employees of the City Government of Makati, accusing them of Plunder and
violation of Republic Act No. (RA) 3019 (Anti Graft and Corrupt Practices Act). On September 9, 2014, the Ombudsman
constituted a Special Panel of Investigators to conduct a fact-finding investigation, submit an investigation report, and file the
necessary complaint, if warranted. On March 11, 2015, a copy of the preventive suspension order was sent to the Office of the
City Mayor, and received by Maricon Ausan, a member of Binay, Jr.'s staff.
In a Resolution dated March 20, 2015, the CA ordered the consolidation of CA-G.R. SP No. 139453 and CA-G.R. SP No. 139504,
and directed the Ombudsman to file her comment thereto. The Ombudsman's argument against the CA's lack of subject
matter jurisdiction over the main petition, and her corollary prayer for its dismissal, is based on her interpretation of Section
14, RA 6770, or the Ombudsman Act. The second paragraph of Section 14, RA 6770 provides that no appeal or application for
remedy may be heard against the decision or findings of the Ombudsman, with the exception of the Supreme Court on pure
questions of law.

Issue: Is the second paragraph of Section 14, RA 6770 insofar as it provides that no appeal or application for remedy may be
heard against the decision or findings of the Ombudsman [except the Supreme Court] on pure questions of law, valid and
constitutional?

Ruling:
No. The second paragraph is invalid and unconstitutional. The appropriate construction of this Ombudsman Act provision is
that all remedies against issuances of the Office of the Ombudsman are prohibited, except the Rule 45 remedy to the Court
on pure questions of law. Since this paragraph limits the remedy against "decision or findings," it attempts to effectively
increase the Supreme Court's appellate jurisdiction without its advice and concurrence in violation of Section 30, Article VI of
the Constitution. This is similar to the fourth paragraph of Section 27 of Republic Act No. 6770 which was strucked down as
unconstitutional. Hence, it is therefore concluded that the provision is also unconstitutional and invalid.

Dela Cruz vs. Ochoa

Recently, the LTO formulated the Motor Vehicle License Plate Standardization Program (MVPSP) to supply the new license
plates for both old and new vehicle registrants. On February 20, 2013, the DOTC published in newspapers of general circulation
the Invitation To Bid for the supply and delivery of motor vehicle license plates for the MVPSP. On July 22, 2013, the DOTC
issued the Notice of Award to JKG-Power Plates, but JKGPower Plates signified its conformed only on August 8, 2013. Although
the contract signing of the project was not immediately undertaken, the DOTC issued the Notice to Proceed to JKG-Power
Plates and directed it to commence delivery of the items within seven (7) calendar days from the date of the issuance of the
said notice. On March 11, 2014, the Senate Committee on Public Services, pursuant to Resolution No. 31, conducted an inquiry
in aid of legislation on the reported delays in the release of motor vehicle license plates, stickers and tags by the LTO. On April
4, 2014, JKG-Power Plates delivered the first batch of plates to the DOTC/LTO. The petitioners filed a petition to assail the
constitutionality of the implementation of the MVPSP using funds appropriated under the 2014 GAA.

Issue: Whether or not the use of the appropriation under 2014 GAA for the implementation of the MVPSP was constitutional
or did it involve an unconstitutional transfer of funds?

Ruling:
The use of the appropriation was constitutional. Pursuant to its legal mandate, the LTO formulated and adopted the MVPSP
in order to supply new standardized license plates for all motor vehicles. In this connection, the DOTC was given the
appropriation for 2014. The Congress appropriated ₱4,843, 753,000.00 for the MF02 (inclusive of the requested increase of
₱2,489,600,100.00) for the purpose of funding the LTO's MVPSP, hence, the inescapable conclusion is that the 2014 GAA itself
contained the direct appropriation necessary to implement the MVPSP.

The implementation of the MVPSP was properly funded under the appropriation for Motor Vehicle Registration and Driver's
Licensing Regulatory Services in the 2014 GAA; thus, no unconstitutionally transfer of funds took place.