Delegation of Powers

1. Trillanes IV v. Medialdea, G.R. No. 241494, April 3, 2024

2. Soliman v. Santos, G.R. No. 202417, July 25, 2023
3. Globe Telecom, Inc. v. National Telecommunications Commission, G.R. No. 200224, February 13, 2023
4. Federation of Jeepney Operators and Drivers Association of the Philippines (FEJODAP), et. al. v. Government of
Manila City, et. al., G.R. No. 209479, July 11, 2023
5. Octaviano v. Board of Architecture of the Professional Regulations Commission, et. al., G.R. No. 239350, August
22, 2023
6. Sobrejuanite-Flores v. Pilando, Jr., G.R. No. 251816. November 23, 2021
7. Belgica v. Ochoa, G.R. No. 208566, November 19, 2013
8. ABAKADA Guro Partylist v. Purisima, G.R. No. 166715, August 14, 2008
9. Southern Cross Cement Corporation v. Cement Manufacturers Association of the Philippines, G.R. No. 158540,
July 8, 2004
10. Eastern Shipping Lines, Inc. v. Philippine Overseas Employment Administration, G.R. No. 76633 October 18,
1988

8.G.R. No. 166715 August 14, 2008

ABAKADA GURO PARTY LIST (formerly AASJS)1 OFFICERS/MEMBERS SAMSON S. ALCANTARA, ED VINCENT S. ALBANO, ROMEO R.
ROBISO, RENE B. GOROSPE and EDWIN R. SANDOVAL, petitioners,
vs.
HON. CESAR V. PURISIMA, in his capacity as Secretary of Finance, HON. GUILLERMO L. PARAYNO, JR., in his capacity as Commissioner
of the Bureau of Internal Revenue, and HON. ALBERTO D. LINA, in his Capacity as Commissioner of Bureau of Customs, respondents.

Facts:
This case is about a petition questioning the constitutionality of Republic Act No. 9335, also known as the Attrition Act of 2005.
The Act aims to improve how the Bureau of Internal Revenue (BIR) and the Bureau of Customs (BOC) collect revenue by
creating a system of rewards and penalties based on performance. It sets up a Rewards and Incentives Fund from extra revenue collected
and forms a Revenue Performance Evaluation Board to manage fund distribution, assess performance, and determine dismissal criteria for underperforming
employees.

The petitioner, ABAKADA GURO PARTY LIST, along with its officers and members, challenges the constitutionality of the Attrition Act of
2005 for several reasons:

1. Representation of Educators: As a party list representing educators, they argue that the Act's focus on financial incentives for
BIR and BOC officials undermines the values of public service and accountability, which are crucial in government roles, including
education.
2. Concerns about Public Service: The petitioners believe the Act transforms BIR and BOC officials into "mercenaries," motivated
primarily by financial rewards rather than a commitment to serve the public interest, which they find concerning for the integrity of
public service.
3. Separation of Powers: They assert that the Act improperly delegates legislative authority to the President, allowing him to set
revenue targets without sufficient guidelines. This undermines the legislative branch's authority and control over fiscal matters,
which should not be ceded to the executive.
4. Lack of Oversight: The creation of a Joint Congressional Oversight Committee, which was declared unconstitutional, is viewed as
an encroachment on the separation of powers, giving the executive branch undue influence over legislative functions, particularly in
revenue generation.

The petitioners argue that the Attrition Act transforms officials in the Bureau of Internal Revenue (BIR) and the Bureau of
Customs (BOC) into "mercenaries." They believe this is because the Act focuses heavily on financial rewards and penalties tied
to revenue performance, which could lead officials to prioritize personal financial gain over their duty to serve the public
effectively. By creating a system where officials are motivated primarily by the prospect of bonuses for meeting revenue targets,
the petitioners contend that the Act undermines the spirit of public service. They are concerned that this could foster a culture
where officials make decisions based more on financial incentives than on ethical considerations or the best interests of the
public. Essentially, they argue that the focus on financial. Additionally, they argue that it improperly gives the President the
authority to set revenue targets without enough guidelines and interferes with the separation of powers by creating a
congressional oversight committee. They believe this undermines the legislative branch's authority by letting the executive
branch have too much control over revenue generation without proper oversight.

Issue:

Whether or not the Attrition Act 2005 (RA 9335) violates the principles of separation of powers and constitutes an improper
delegation of legislative authority by allowing the President to set revenue targets without adequate guidelines.

Decision:

The Supreme Court partially granted the petition challenging the constitutionality of Republic Act No. 9335, known as the Attrition Act of 2005.
It declared Section 12, which created a Joint Congressional Oversight Committee to approve the law's implementing rules, unconstitutional
and null and void. However, the Court upheld the constitutionality of the remaining provisions, affirming their role in enhancing revenue
collection by the Bureau of Internal Revenue (BIR) and the Bureau of Customs (BOC). The Court found that the Act improperly delegated
legislative authority to the President by allowing him to set revenue targets without adequate guidelines, undermining the legislative branch's
control over fiscal matters. Additionally, the establishment of the oversight committee was seen as an infringement on the separation of
powers, giving the executive branch undue influence over revenue generation, which is traditionally a legislative function. The lack of clear
standards for the President's determination of revenue targets raised concerns about arbitrary decision-making. Ultimately, the Court deemed
the delegation of authority through Section 12 unconstitutional, emphasizing the importance of maintaining checks and balances within the
government.

G.R. No. 208566 November 19, 2013

GRECO ANTONIOUS BEDA B. BELGICA JOSE M. VILLEGAS JR. JOSE L. GONZALEZ REUBEN M. ABANTE and QUINTIN PAREDES SAN
DIEGO, Petitioners,
vs.
HONORABLE EXECUTIVE SECRETARY PAQUITO N. OCHOA JR. SECRETARY OF BUDGET AND MANAGEMENT FLORENCIO B. ABAD,
NATIONAL TREASURER ROSALIA V. DE LEON SENATE OF THE PHILIPPINES represented by FRANKLIN M. DRILON m his capacity as SENATE
PRESIDENT and HOUSE OF REPRESENTATIVES represented by FELICIANO S. BELMONTE, JR. in his capacity as SPEAKER OF THE
HOUSE, Respondents.

Facts of the Case

The case addresses the constitutionality of the "Pork Barrel System" in the Philippines, particularly focusing on the Priority
Development Assistance Fund (PDAF) and discretionary presidential funds amidst public outrage over corruption and misuse.
Background: The term "Pork Barrel" refers to discretionary funds allocated to lawmakers, historically associated with kickbacks
and corruption. Public anger surged following the Napoles controversy, where billions were reportedly misappropriated through
ghost projects.
CoA Report Findings: A Commission on Audit (CoA) report highlighted widespread irregularities in PDAF usage from 2007 to 2009,
including excessive fund releases and improper handling by NGOs.

Allegations: Whistle-blowers claimed that around ₱10 billion was misappropriated through ghost projects funded by lawmakers,
notably involving Janet Lim Napoles and her network of dummy NGOs.
Petitions Filed:
Alcantara Petition: Filed on August 28, 2013, by Samson S. Alcantara, seeking to declare the Pork Barrel System unconstitutional
and restraining legislative appropriations. Belgica Petition: On September 3, 2013, Greco Antonious Beda B. Belgica and others
sought to declare the PDAF and presidential discretionary funds unconstitutional, requesting a TRO to halt expenditures.
Nepomuceno Petition: On September 5, 2013, Pedrito M. Nepomuceno requested a declaration of PDAF's unconstitutionality and a
restraining order against fund releases. Court Actions: On September 10, 2013, the Supreme Court consolidated the cases, issued
a TRO against PDAF and Malampaya Funds, and scheduled oral arguments for October 8, 2013. Government Response: The Office
of the Solicitor General sought to lift the TRO for certain purposes and argued for the dismissal of the petitions. Oral Arguments
and Further Proceedings: Oral arguments were conducted in October 2013, with the Court requesting memoranda from the parties
involved.
The Issues Before the Court
The main issues for the Court’s resolution, as refined during the Oral Arguments, are as follows:
Procedural Issues:
Whether (a) the issues raised in the consolidated petitions involve an actual and justiciable controversy; (b) the issues are matters
of policy not subject to judicial review; (c) the petitioners have legal standing to sue; and (d) previous Supreme Court decisions bar
re-litigation of the constitutionality of the "Pork Barrel System" under res judicata and stare decisis principles.
Substantive Issues on the Congressional Pork Barrel:
Whether the 2013 PDAF Article and other similar Congressional Pork Barrel Laws are unconstitutional for violating principles of (a)
separation of powers; (b) non-delegability of legislative power; (c) checks and balances; (d) accountability; (e) political dynasties;
and (f) local autonomy.
Substantive Issues on the Presidential Pork Barrel:
Whether the phrases “and for such other purposes as may be hereafter directed by the President” under Section 8 of PD 910
(Malampaya Funds) and “to finance the priority infrastructure development projects and to finance the restoration of damaged or
destroyed facilities due to calamities, as may be directed and authorized by the Office of the President of the Philippines” under
Section 12 of PD 1869 (Presidential Social Fund) are unconstitutional as they constitute undue delegations of legislative power.
Conclusion
The Court renders this Decision to rectify a long-standing error in Philippine governance. Ultimately, the Court declares the Pork
Barrel System unconstitutional due to several inherent defects. The system has violated the principle of separation of powers by
allowing legislators to wield non-oversight authority in budget execution. It has also contravened the principle of non-delegability
of legislative power by granting legislators personal, discretionary funds to determine project funding, flouted procedural
requirements by not textualizing budget items, impaired public accountability, and undermined local autonomy.
Given these constitutional violations, the Court finds that:
The entire 2013 PDAF Article and all similar provisions in Congressional Pork Barrel Laws are unconstitutional. Specific phrases in
the Malampaya Funds and Presidential Social Fund that allow for broad discretionary appropriations are also declared
unconstitutional. The Court's temporary injunction from September 10, 2013, is made permanent, thereby enjoining the
disbursement of remaining PDAF funds and other related funds not covered by appropriate legal frameworks. However, the
petitioners' request for the government to release detailed reports on fund utilization is denied due to lack of substantiation.
Moreover, the Court directs government prosecutorial bodies to investigate and prosecute potential criminal offenses related to the
misuse of funds under the Pork Barrel System. This Decision is immediately executory but has a prospective effect, urging a shift
towards adherence to the rule of law and constitutional governance, while acknowledging the past and looking towards a more
accountable future.

Belgica v. Ochoa | Case Digest

FACTS: The case revolves around the historical context of the Pork Barrel System in the Philippines, tracing its origins back to the 1922
Public Works Act. Over the decades, various iterations of the pork barrel, including the Countrywide Development Fund (CDF) and the
Priority Development Assistance Fund (PDAF), have allowed legislators significant control over budget execution, leading to allegations of
corruption and misuse of funds. The pork barrel system faced scrutiny following revelations of kickbacks and misappropriation of public funds,
particularly concerning ghost projects and non-governmental organizations.

ISSUES: The case presented both procedural and substantive issues:

1. Procedural Issues:
o Existence of an actual and justiciable controversy.
o Whether the matter is a political question not subject to judicial review.
o Legal standing of the petitioners.
o Previous rulings preventing re-litigation of the Pork Barrel system's constitutionality.
2. Substantive Issues:
o Constitutionality of the 2013 PDAF Article and other pork barrel laws in relation to separation of powers, non-delegability
of legislative power, checks and balances, accountability, political dynasties, and local autonomy.

DECISION: The Court found that:

 There is an actual controversy regarding the constitutionality of the pork barrel system.
 The political question doctrine does not apply, as the issue requires judicial interpretation of constitutional provisions.
 Petitioners, as taxpayers and citizens, have standing to challenge the laws.
 The previous rulings do not bar this case as they dealt with specific issues not encompassing the broader examination required
here.

On substantive grounds, the Court ruled that the Pork Barrel System, particularly the 2013 PDAF Article, violates constitutional principles,
including:

 Separation of Powers: Legislators’ roles in post-enactment budget execution infringe on executive functions.
 Non-Delegability of Legislative Power: Individual legislators exercising appropriation powers contravenes the Constitution.
 Checks and Balances: The system fosters potential conflicts of interest and undermines accountability.
 Local Autonomy: The Pork Barrel system undermines local governance structures.

The Court declared the 2013 PDAF Article and related provisions unconstitutional, and the injunction against the release of PDAF funds was
made permanent. Further, the Court directed investigations into the misuse of funds and denied some procedural requests from the
petitioners.

1. Trillanes IV v. Medialdea, G.R. No. 241494, April 3, 2024

KEYWORDS: OAKWOOD MUTINY 2003/ AMNESTY PN 75 and PN 572
Facts
Antonio F. Trillanes IV, a former Lieutenant Senior Grade in the Philippine Navy, played a significant role in military uprisings that
challenged the Philippine government. He led the Oakwood Mutiny on July 27, 2003, where members of the Magdalo Group
occupied the Oakwood Premier Apartments, resulting in charges of coup d'état (Criminal Case No. 03-2784). Later, on
November 29, 2007, Trillanes and his associates staged a dramatic walkout during a court hearing and occupied the Manila
Peninsula Hotel, leading to additional charges of rebellion (Criminal Case No. 07-3126). Despite these legal challenges, he was
elected to the Philippine Senate in 2007 while the coup d'état case was still pending.
In an effort to promote reconciliation, President Benigno Aquino III issued Proclamation No. 75 on November 24, 2010, granting
amnesty to individuals involved in the Oakwood Mutiny and related incidents. This proclamation included specific requirements
for amnesty, such as a written admission of guilt, and established a committee to process applications. Although Trillanes
allegedly did not formally apply for amnesty or admit guilt, he was included among those granted amnesty.

In 2018, President Duterte issued Proclamation No. 572, declaring Trillanes's amnesty void due to non-compliance with
application requirements. This proclamation prompted law enforcement to pursue Trillanes for his earlier charges, leading to a
failed arrest attempt in the Senate building on September 4, 2018. In response, Trillanes filed a petition challenging the validity of
Proclamation No. 572, asserting that it infringed on his rights.

Proclamation No. 572, issued by President Rodrigo Duterte on September 4, 2018, declared the amnesty granted to Antonio F.
Trillanes IV under Proclamation No. 75 void. The proclamation argued that Trillanes had failed to comply with the application
requirements, specifically the written admission of guilt. As a result, it directed law enforcement to pursue Trillanes for his earlier
charges, leading to attempts to arrest him. This action sparked legal challenges regarding its constitutionality, particularly
concerning due process and equal protection rights.

Issues
Whether the President has the legitimate authority to grant amnesty, focusing on the constitutionality of Proclamation No. 75 and
voiding of Proclamation No. 572.

Ruling
Ultimately, the Court granted Trillanes's petition, voiding Proclamation No. 572 and reinforcing the importance of constitutional
protections and legislative oversight in significant executive actions. The Supreme Court ruled in favor of Antonio F. Trillanes IV
on multiple issues, deciding that his Certiorari Petition should not be dismissed for forum shopping or notarization defects, as the
matters raised warranted judicial review. The Court found that Trillanes did not violate the hierarchy of courts by filing directly
with the Supreme Court, recognizing the urgency and constitutional implications of his case, which required immediate judicial
attention.

In upholding the constitutionality of Proclamation No. 75, the Court affirmed the executive's legitimate authority to grant amnesty
as a crucial tool for reconciliation and national healing. This power, while significant, is also bounded by constitutional limits and
the necessity for due process. The Court emphasized that the executive must exercise its powers within the framework of the
law, ensuring that such actions do not infringe on individual rights. Conversely, the declaration of Proclamation No. 572 as
unconstitutional highlighted the importance of protecting due process and equal protection under the law. The Court found that
the revocation of Trillanes's amnesty was arbitrary, as it unfairly singled him out among other grantees, undermining the principle
of equal treatment under the law. This ruling underscore the delicate balance of powers within the government and the need for
oversight to prevent any potential abuse of executive authority.

The amnesty granted under Proclamation No. 75 was constitutional because it fell within the President's legitimate authority
to promote national reconciliation after periods of conflict. The proclamation clearly outlined the criteria for amnesty,
ensuring it was not an arbitrary exercise of power, and did not unlawfully delegate this authority to any other entity. By
establishing guidelines that included a written admission of guilt, the proclamation aimed to facilitate healing and encourage
accountability among those involved in past uprisings, thereby supporting the broader goal of restoring peace and stability in the
nation.

2. Soliman v. Santos, G.R. No. 202417, July 25, 2023

Soliman v. Santos, G.R. No. 202417, July 25, 2023

Facts: This case centers on the obligation of non-profit golf and country clubs to grant a 20% discount to senior
citizens on fees and services, as mandated by the Expanded Senior Citizens Act (RA 9994). The Manila Southwoods
Golf and Country Club argued against this requirement, citing the implementing rules which exempt certain private
clubs from the discount obligation. In contrast, Carlos T. Santos, Jr. asserted that the law clearly entitles senior
citizens to discounts in recreation centers, including golf clubs, and that membership status should not negate this
entitlement. The Regional Trial Court ruled in favor of Santos, declaring the exemption invalid and highlighting the
law's purpose of alleviating economic pressures on seniors. This ruling prompted appeals from both the Department
of Social Welfare and Development (DSWD) and the Manila Southwoods Golf and Country Club, leading to a
thorough examination of the legality of the implementing rules versus the statutory requirements of RA 9994.

Issue: The critical issue at stake was whether the provision in the Implementing Rules and Regulations (IRR) of RA
9994 that exempts non-profit golf and country clubs from providing the mandated 20% senior citizen discount is
legally valid. Additionally, the court needed to determine how this discount applies to membership dues versus fees
for services.

Decision: The Supreme Court ruled that the provision in the DSWD's IRR that exempts certain services from the
required discount is invalid. While the court acknowledged that associations are not mandated to offer discounts on
membership dues, it clarified that they must provide the 20% discount on relevant services such as locker rentals and
golf cart usage, as required by RA 9994. The ruling reinforces the intent of the law to support senior citizens by
ensuring they receive discounts on applicable services, thus rejecting any blanket exemptions that could undermine
this purpose.

Delegation of Powers
G.R. No. 76633 October 18, 1988
EASTERN SHIPPING LINES, INC., petitioner,
vs.
PHILIPPINE OVERSEAS EMPLOYMENT ADMINISTRATION (POEA), MINISTER OF LABOR AND EMPLOYMENT,
HEARING OFFICER ABDUL BASAR and KATHLEEN D. SACO, respondents

FACTS OF THE CASE:

The private respondent, Kathleen D. Saco, was awarded P192,000.00 by the Philippine Overseas Employment
Administration (POEA) for the death of her husband, Vitaliano Saco, who was the Chief Officer of the M/V Eastern
Polaris and was killed in an accident in Tokyo, Japan, on March 15, 1985. His widow filed for damages under
Executive Order No. 797 and Memorandum Circular No. 2 of the POEA. The petitioner, the vessel's owner, contested
the POEA's jurisdiction, claiming that Saco was not an overseas worker but a domestic employee, asserting that the
complaint should have been filed with the Social Security System against the State Insurance Fund.
The POEA assumed jurisdiction, ruling in favor of the complainant, awarding P180,000.00 for death benefits and
P12,000.00 for burial expenses. The petitioner sought to dismiss the ruling on the grounds of non-exhaustion of
administrative remedies but acknowledged that the main questions raised were essentially legal.
THE MAIN ISSUE:
The primary issue before the Court was whether the POEA had the authority to adjudicate the claims of the widow,
particularly concerning the validity of Memorandum Circular No. 2, which was challenged by the petitioner as a
violation of the principle of non-delegation of legislative power. The petitioner argued that the POEA lacked the
authority to issue regulations and that such delegation of legislative powers was invalid.
DECISION OR RULING:
The Supreme Court ruled that the POEA did have jurisdiction over the case, affirming that Vitaliano Saco was an
overseas employee at the time of his death. The Court found that the definitions and regulations provided by the
POEA applied to Saco's situation, as he was working under a valid contract while on board the vessel in a foreign
country.
Regarding the delegation of powers, the Court upheld the validity of Memorandum Circular No. 2, clarifying that the
authority to issue regulations was explicitly granted to the POEA by Executive Order No. 797. The Court concluded
that while the legislature cannot delegate its substantive powers, it can delegate authority for the enforcement of laws,
and the POEA's regulations were deemed necessary for the effective implementation of policies aimed at protecting
overseas Filipino workers.
Ultimately, the petition was dismissed, with the Court emphasizing the importance of protecting the rights of workers,
especially in light of social justice considerations. The temporary restraining order issued was lifted, and costs were
ordered against the petitioner.

Globe Telecom, Inc. v. National Telecommunications Commission, G.R. No. 200224 with the original case
details:

FACTS
 Due Process Requirement: The NTC must allow telecommunications companies to express concerns or
seek reconsideration before imposing rates.
 Consolidated Petitions: Four telecommunications companies challenged the NTC's authority to implement a
new six-second-per-pulse billing scheme established in July 2009, which replaced the prior one-minute billing
system.
 NTC Orders: The NTC provisionally authorized several companies to adopt the new billing rates, requiring
compliance and submission of proposed rates.
 Billing Adjustments: Companies were mandated to adjust rates based on the new scheme, affecting call
types like call forwarding and teleconferencing.
 Compliance Advisories: Globe and Innove, along with Smart Communications, published advisories
confirming their compliance with the new billing system.
  Show Cause Orders: On December 9, 2009, the NTC issued Show Cause Orders against several
companies for non-compliance with the new billing directive.
 Cease and Desist Orders: These orders directed companies to stop using the previous billing system and
refund subscribers for overcharges until compliance was achieved.
 Legal Challenges: Telecommunications companies argued that the NTC's Orders were punitive and violated
due process.
 Court of Appeals Proceedings: The petitions were consolidated, and the Court of Appeals issued
resolutions including temporary restraining orders against the NTC's enforcement of its December orders.
ISSUE
Whether the NTC has the authority to impose rates on Cellular Mobile Telephone Service (CMTS) providers,
particularly regarding the validity of the six-second-per-pulse billing scheme and the prohibition on using prefixes, as
well as the lawfulness and adherence to due process of its December 5 and 9, 2009 Orders.
RULING
 Court of Appeals Decision: The Court reversed the NTC's December 2009 orders, citing due process
violations as the NTC imposed fixed rates without considering evidence from the telecommunications
companies and failed to provide time for reconsideration.
 Permanent Injunction: The Court made the temporary injunction against enforcing the NTC's orders
permanent, upholding the importance of due process in regulatory actions.
 Authority to Regulate: The Court acknowledged the NTC's statutory authority but emphasized that such
power must not override the fundamental rights of telecommunications companies, highlighting the need for a
balance between regulatory authority and due process.
 February 13, 2023 Update: The Supreme Court reaffirmed the necessity of due process in the NTC’s
regulatory actions, emphasizing that companies must be given the opportunity to voice concerns before rate
impositions. It upheld the permanent injunction against the NTC's orders related to the six-second billing
scheme, reinforcing the requirement for regulatory agencies to consult affected parties before implementing
significant changes.