BAYAN MUNA CHAIRMAN NERI COLMENARES, BAYAN MUNA VICE CHAIRMAN TEODORO A. CASIÑO, BAYAN MUNA EXECUTIVE VICE PRESIDENT CARLOS ISAGANI T. ZARATE, AND FORMER BAYAN MUNA REPRESENTATIVE FERDINAND R. GAITE, PETITIONERS, VS. * EXECUTIVE SECRETARY LUCAS P. BERSAMIN, SENATE OF THE PHILIPPINES AND THE HOUSE OF…
- G.R. Number: G.R. No. 275405
- Promulgated: 2025-12-03
Doctrine
## Facts of the Case In the Philippines, a significant portion of healthcare expenses are paid out-of-pocket by families, highlighting a critical gap in accessible healthcare. To address this, Republic Act No. 10351 (Sin Tax Reform Law) was enacted in 2012, earmarking excise taxes on alcohol and tobacco products for universal healthcare and government subsidies to the premium contributions of indigents under the National Health Insurance Program (NHIP). This law was later amended to include excise tax on heated tobacco and vapor products. In 2019, Republic Act No. 11223, or the Universal Health Care Act (UHCA), further expanded social health insurance, automatically covering every Filipino citizen and mandating comprehensive health services. The UHCA explicitly listed total incremental sin tax collections as a primary source of appropriations for its implementation. Subsequent amendments to the National Internal Revenue Code (NIRC) further reserved portions of sin tax revenues for UHCA implementation. In 2023, President Ferdinand R. Marcos, Jr. submitted the national budget for fiscal year 2024 to Congress. House Bill No. 8980, which adopted the President's budget, was certified as urgent and approved by both the House of Representatives and the Senate. The Bicameral Conference Committee (BCC) then increased unprogrammed appropriations and inserted Special Provision 1(d) under Chapter XLIII of the General Appropriations Act of 2024 (2024 GAA). This provision authorized the return of "fund balance" or "excess reserve funds" of Government-Owned and Controlled Corporations (GOCCs) to the National Treasury to fund unprogrammed appropriations. The Department of Finance (DOF) was tasked to issue implementing guidelines. On December 20, 2023, President Marcos, Jr. signed House Bill No. 8980 into law as **Republic Act No. 11975** (2024 GAA). Pursuant to Special Provision 1(d), the DOF issued **DOF Circular No. 003-2024** on February 27, 2024, requiring GOCCs like the **Philippine Health Insurance Corporation (PhilHealth)** to remit their fund balance to the National Treasury. Subsequently, DOF Secretary Ralph G. Recto instructed PhilHealth to remit PHP 89.9 billion, representing its excess "reserve funds" from government subsidy contributions for indigents from 2021-2023. PhilHealth complied, remitting PHP 20 billion on May 10, 2024, PHP 10 billion on August 21, 2024, and PHP 30 billion on October 16, 2024, for a total of PHP 60 billion. On September 20, 2025, President Marcos, Jr. announced that the PHP 60 billion remitted by PhilHealth would be returned to the corporation. Petitioners, including Senator Aquilino Pimentel III, various labor groups, and medical associations, filed consolidated petitions for certiorari and prohibition, challenging the constitutionality of Special Provision 1(d) of the 2024 GAA and DOF Circular No. 003-2024. ## Issues 1. Whether Special Provision 1(d) of Republic Act No. 11975 (2024 GAA) is unconstitutional. 2. Whether Department of Finance (DOF) Circular No. 003-2024 is unconstitutional. ## Decision / Rationale [The provided text does not contain the Court's decision or rationale for the issues raised.] ## Doctrines [The provided text does not contain the doctrines applied by the Court.]