PHILIPPINE CONSTITUTION ASSOCIATION, EXEQUIEL B. GARCIA and A. GONZALES, vs. HON. SALVADOR ENRIQUEZ, as Secretary of Budget and Management; HON. VICENTE T. TAN, as National Treasurer and COMMISSION ON AUDIT.
- G.R. Number: G.R. No. 113105
- Promulgated: 1994-08-19
- Ponente: Quiason, J.
Doctrine
Members of Congress may propose and identify projects in appropriation acts, but such proposals are recommendatory; the President examines qualifications and implements funded projects under the GAA.
Individual members of either House have legal standing to challenge a presidential veto or conditions imposed on appropriation items.
The President's issuance of administrative guidelines on the use of public funds is an exercise of the Faithful Execution Clause allowing necessary and proper steps to carry laws into execution; validity depends on the actual guidelines issued.
Facts
Taxpayers and several Senators sought judicial review claiming Congress and the President exceeded their authorities in the enactment and veto of appropriations provisions, raising clashes between the purse and the sword.
The Court invited former justices to file amicus memoranda because of the importance and novelty of the issues presented in the four petitions.
The Court held that an individual member of either House has legal standing to question the validity of a presidential veto or a condition imposed on an appropriation item.
Under Article XLI of the 1994 GAA, members of Congress may propose and identify projects for implementation, but such proposals are recommendatory; the President examines qualification and implements funded projects.
Issues
Whether a member of Congress has standing to challenge the validity of a presidential veto or a condition imposed on an appropriation item.
Whether the President exceeded the item-veto power by vetoing provisions of an Appropriations Bill — i.e., whether the President may veto 'provisions' as distinct from 'items.'
Whether expenditures subject to executive-issued guidelines are proper exercises of the President's duty to see that laws are faithfully executed.
Ruling
The petitions are DISMISSED generally, except limited relief granted in specified petitions: G.R. Nos. 113105 and 113766 insofar as they annul the veto of the special provision on debt service, and limited relief in G.R. No. 113888 as detailed.
The Court ruled that individual members of the Senate and House have legal standing to question the validity of a presidential veto or a condition on an appropriation item.
The President may issue administrative guidelines on the use of public funds as part of his constitutional duty to faithfully execute the laws; propriety of such guidelines cannot be assessed until issued.
Keywords
G.R. No. 113105, G.R. No. 113174, G.R. No. 113766, G.R. No. 113888, Philippine Constitution Association, writ of prohibition, GAA of 1994, Republic Act No. 7663, Presidential Veto Message, veto power, Countrywide Development Fund, Appropriation for Debt Service, writ of certiorari, writ of mandamus, judicial review, locus standi, conditions imposed by the President, special provision, General Appropriation Bill of 1994, president